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New Limited Remuneration Exception and Additional Tools to Ensure Compliance with the Stark Law

The Situation: On November 20, 2020, the Centers for Medicare & Medicaid Services ("CMS") released the long-awaited final rule to modernize and clarify the Stark Law. As part of this final rule, CMS reviewed stakeholder...more

CMS Proposes New Limitations to the Isolated Transactions Exception to the Stark Law

The Situation: The isolated transactions exception under the Stark Law has been used by some providers and entities to retroactively protect services arrangements that do not qualify for personal services or market value...more

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