Clearing up some of the confusion surrounding deadlines for compliance, CMS issued proposed rules for implementation of the health care reform legislation changes to the whole hospital and rural provider exceptions to the Stark Law as part of the Cost Year (CY) 2010 OPPS/ASC Proposed Rule. The health care reform legislation amended the rural provider and "whole hospital" ownership exceptions to effectively bar future physician investment in hospitals, while providing a limited grandfathering provision for existing hospitals that have

physician investment and a provider agreement by December 31, 2010. Ober|Kaler's Julie E. Kass and Kristin Cilento Carter discuss the proposed rules.