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Compliance Compass: The Erlanger Complaint – A Cautionary Reminder About the Importance of FMV

Although most health care lawyers and compliance officers who review and analyze physician compensation understand that fair market value (FMV) is important, the nuances around FMV are sometimes missed....more

CMS Changes Medicare Advantage and Part D Plans’ Agent/Broker/TPMO Compensation Landscape

In its November 2023 Proposed Rule and in its recently issued Final Rule that will be published in the Federal Register later this month, the Centers for Medicare & Medicaid Services (CMS) addressed concerns related to agent...more

“Let’s Talk Compliance”: Hot Topics in Compliance

Editor’s Note: PYA and Foley & Lardner hosted the 6th Annual “Let’s Talk Compliance” two-day Virtual Conference on January 18 and 19, 2024. Panelists included Foley & Lardner attorneys and PYA experts. The event was hosted by...more

Stark Law Changes: Hospitals Need to Revisit Physician Compensation Arrangements

Based on recent changes and clarifications made by the Centers for Medicare and Medicaid Services (CMS) in the Federal Physician Self-Referral Law (commonly known as the “Stark Law”), hospitals and health systems need to...more

Key Takeaways from the Revised and Clarified Stark Law Regulations – Part 2

CMS made impactful changes to the Federal physician self-referral law’s (i.e., Stark Law’s) regulations in its Final Rule that were effective January 19, 2021 (with the exception of the changes to 42 C.F.R. § 411.352(i) that...more

Key Takeaways from the Revised and Clarified Stark Law Regulations – Part 1

CMS made impactful changes to the Federal physician self-referral law’s (i.e., Stark Law’s) regulations in its Final Rule that were effective January 19, 2021 (with the exception of the changes to 42 C.F.R. § 411.352(i) that...more

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