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A Starkly Different Landscape – A Deep Dive Into CMS’ Recently Proposed Amendments to the Stark Law

On October 17, 2019, the Centers for Medicare & Medicaid Services (“CMS”) published a Notice of Proposed Rulemaking in the Federal Register (“Proposed Rule”), modifying the regulations implementing the federal physician...more

CMS Finalizes Two New Exceptions and Other Modifications to the Stark Law

On October 30, 2015, the Centers for Medicare and Medicaid Services (“CMS”) posted a final rule, which was published in the Federal Register on November 16, 2015 (“Final Rule”), modifying the regulations implementing the...more

The “Cross-Your-Fingers-And-Hope-It-Goes-Away” School of Statutory Interpretation”: Recent D.C. Circuit Opinion Orders HHS To...

On June 12, 2015, the U.S. Court of Appeals for the District of Columbia (the “Court”) issued an opinion questioning the Department of Health & Human Services’ (“HHS”) interpretation of congressional intent when it...more

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