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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

CMS Addresses Common Questions Regarding Stark Waivers for COVID-19 Purposes

The COVID-19 pandemic has created the need for flexibility in physician arrangements during the public health emergency. In response to that need, the Centers for Medicare and Medicaid Services (“CMS”) issued Stark waivers,...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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