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HRSA Issues First Round of Final Repayment Notices for Certain Provider Relief Fund Recipients

The Health Resources & Service Administration (“HRSA”) has begun issuing Final Repayment Notices to providers who received Provider Relief Funds (“PRF”) under the following circumstances: Providers who rejected the Terms and...more

Increased Enforcement Activity Expected Relating to Healthcare Provider Billing Upcoding

A pair of recent reports issued by the Health and Human Services Office of Inspector General (“OIG”) and Cotiviti, a Centers for Medicare and Medicaid Services (“CMS”) Recovery Audit Contractor (“RAC”), indicate a resumed...more

CMS Finalizes Major Stark Law Rule

The Centers for Medicare & Medicaid Services (“CMS”) delivered welcome news in advance of the Thanksgiving holiday by issuing its final rule (the “Final Rule”) on November 20, 2020 to amend current regulations interpreting...more

Murky Waters – The Stark Controversy in Hospital-Physician Relationships

Since the completion of this article, CMS has announced that its final Stark law rule will be published in the Federal Register on December 2, 2020. I. Introduction - The Stark Law has been litigated for the past two...more

HHS Announces $20B Phase 3 Provider Relief Fund to Begin on October 5, 2020

The Department of Health and Human Services (“HHS”) announced a new round of Provider Relief Funds on October 1, 2020. This new Phase 3 of Provider Relief Funding will distribute a total of $20 billion to eligible providers....more

CMS Announces Reevaluation and Suspension of the Accelerated and Advance Payment Programs

The Centers for Medicare & Medicaid Services (“CMS”) surprised stakeholders on Sunday, April 26, with an announcement that it would be reevaluating the amounts that will be paid under its Accelerated Payment Program and...more

HHS Publishes Provider Relief Fund FAQ and Further Guidance

The Department of Health and Human Services (“HHS”) continues to provide guidance and instruction regarding the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act Provider Relief Fund....more

Breaking News – HHS Announces Further Plans for Provider Relief Fund Monies

The Department of Health and Human Services (“HHS”) announced plans for additional allocations of the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act Provider Relief Fund on Wednesday, April 22, 2020. The CARES...more

A Guide to the CARES Act Medicare Provider Relief Fund

The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act provides $100 billion in relief funds to hospitals and health care providers to aid in their coronavirus response. From those monies, the Department of Health...more

CMS Issues Stark Waivers for COVID-19 Purposes

CMS issued new Stark waivers on Monday evening, March 30, giving providers unprecedented flexibility to manage arrangements through the COVID-19 pandemic. While regulatory requirements are still in effect and these waivers...more

CMS Publishes Final Rule Announcing New Enrollment and Participation Enforcement Authorities

The Centers for Medicare & Medicaid Services (“CMS”) recently issued a final rule with comment period (CMS-6058-FC) implementing statutory provisions that afford CMS new denial and revocation authorities related to Medicare...more

Proposed Coordinated Care Revisions to the Medicare Physician Self-Referral Law

The Centers for Medicare & Medicaid Services (“CMS”) issued a proposed rule (“Proposed Rule”) on October 9, 2019 to amend current regulations interpreting the Medicare physician self-referral law (the “Stark” law).  ...more

CMS Continues to Eye Reforms to Stark Law, Requests Public Input

The Centers for Medicare and Medicaid Services (CMS) issued a Request for Information (RFI) on June 20, 2018 seeking input from the public on how to address “any undue regulatory impact and burden” of the physician...more

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