CMS Proposes Changes to Physician Self-Referral Regulations to Promote Value-Based Health Care

Akin Gump Strauss Hauer & Feld LLP

[co-authors: Caroline Kessler, Law Clerk and Julie Nolan, Senior Policy Advisor]

Key Points:

  • The Centers for Medicare and Medicaid Services (CMS) have issued a long-awaited proposal to reform the Physician Self-Referral Law’s (Stark Law’s) regulatory exceptions and to provide updated guidance for physicians and health care providers and suppliers whose financial relationships are subject to the Stark Law.
  • The goals of these reforms are to modernize and clarify the Stark Law regulations in order to (a) alleviate the undue impact of the Stark Law on parties that participate in alternative payment models and other novel financial arrangements, (b) better facilitate patient care coordination and management among providers and other health care delivery partners, and (c) advance the transition from a payment model that compensates on a fee-for-service basis to one that rewards quality outcomes and value achieved.
  • Simultaneously, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released its own highly anticipated proposed reforms to the Anti-Kickback Statute safe harbors, also with the goal of advancing value-based care. Akin Gump’s Client Alert on the Anti-Kickback Statute proposals is available here.
  • Comments to CMS’s proposal are due Dec. 31, 2019.

Discussion:

On October 9, 2019, CMS issued a proposed rule to update the Stark Law’s regulatory exceptions.1 With this proposed rule, CMS aims to update the Stark Law regulations to better reflect the realities and trends of modern health care. The following are some of the most significant proposals:

  • First, CMS proposes to update the Stark Law regulations to create new exceptions for “value-based arrangements” (as defined below) in order to better facilitate innovation and enable the transformation of the health care system towards value-based care—and away from a fee-for-service model of payment.
  • Second, CMS is seeking comments on the role of price transparency in the context of the Stark Law and whether to require cost-of-care information at the point of referral for an item or service.
  • Third, CMS hopes to continue to facilitate the adoption of electronic health record (EHR) technology and decrease cybersecurity risk in the health care industry by providing greater flexibility to existing Stark Law exceptions and through the creation of a new exception for the donations of certain cybersecurity technology.
  • Fourth, CMS proposes to clarify terminology and concepts critical to the Stark Law in order to ease some of the considerable burden of compliance with the self-referral law and regulations.

CMS proposed changes to make it clear that the agency, while focused on preventing abuse, is emphasizing innovation in health care and seeking to identify and address any undue impacts and burdens of compliance with the Stark Law. In addition, with the proposed regulation, CMS aims to promote coordination and alignment with the OIG’s concurrently released proposed Anti-Kickback safe harbor rule in order to ease the compliance burden in the industry.

New Exceptions for Value-Based Arrangements

To facilitate the new value-based exceptions, CMS proposes new defined terms (42 CFR § 411.351).

In the rulemaking, CMS proposed to create three new exceptions for value-based arrangements. These exceptions apply “regardless of whether the arrangement relates to care furnished to Medicare beneficiaries, non-Medicare patients, or a combination of both.”2

1. Full Financial Risk Exception (Proposed 42 CFR § 411.357(aa)(1)): This exception protects remuneration paid under a value-based arrangement between VBE participants in a value-based enterprise that has assumed “full financial risk” for the cost of all patient care items and services covered by the applicable payor for each patient in the target population for a specified period of time. To satisfy this exception, VBE participants must meet the following requirements:

  • The value-based enterprise is financially responsible (or is contractually obligated to be financially responsible within the first six months of the arrangement) for the cost of all patient care items and services (e.g., via capitation payments or global budget payments).
  • The financial risk must be prospective.
  • The remuneration is for or results from value-based activities undertaken by the recipient of the remuneration for patients in the target patient population.
  • The remuneration is not an inducement to reduce or limit medically necessary items or services.
  • The remuneration is not conditioned on referrals of patients who are not part of the target patient population or business not covered under the arrangement (unless the arrangement meets certain specified requirements).
  • Records of the methodology for determining the amount of remuneration and the actual amount of remuneration paid under the arrangement must be retained for at least six years.

2. Meaningful Downside Financial Risk Exception: (Proposed 42 CFR § 411.357(aa)(2)): This exception protects remuneration paid under a value-based arrangement if the physician is at meaningful downside financial risk for failure to achieve the value-based purpose(s) of the value-based enterprise during the entire duration of the value-based arrangement. To satisfy this exception, the parties must meet the following requirements:

  • The physician is responsible to pay the entity no less than 25 percent of the value of the remuneration the physician receives under the value-based arrangement or is financially responsible to the entity on a prospective basis for the cost of all or a defined set of patient care items or services.
  • A description of the nature and extent of the physician’s downside risk is set forth in writing.
  • The methodology used to determine the amount of remuneration is set in advance.
  • The remuneration is for, or results from, value-based activities undertaken by the recipient of the remuneration for patients in the target patient population.
  • The remuneration is not an inducement to reduce or limit medically necessary items or services.
  • The remuneration is not conditioned on referrals of patients who are not part of the target patient population or business not covered under the arrangement (unless the arrangement meets certain specified requirements).
  • Records of the methodology for determining the amount of remuneration and the actual amount of remuneration paid under the arrangement must be retained for at least six years.

3. Value-Based Arrangements Exception: (Proposed 42 CFR § 411.357(aa)(3)): This exception protects remuneration paid under a value-based arrangement if the following conditions are met:

  • The arrangement is set forth in writing and signed by the parties. The writing includes a description of:
    • The value-based activities to be undertaken.
    • How the value-based activities are expected to further the value-based purpose of the value-based enterprise.
    • The target patient population.
    • The type or nature of the remuneration.
    • The methodology used to determine the remuneration.
    • The performance or quality standards against which the recipient will be measured.
  • The performance or quality standards used are objective and measurable, and any changes to the standards must be made prospectively and in writing.
  • The methodology used to determine the amount of the remuneration is set in advance.
  • The remuneration is for, or results from, value-based activities undertaken by the recipient of the remuneration for patients in the target patient population.
  • The remuneration is not an inducement to reduce or limit medically necessary items or services.
  • The remuneration is not conditioned on referrals of patient who are not part of the target patient population or business not covered under the arrangement (unless the arrangement meets certain specified requirements).
  • Records of the methodology for determining the amount of remuneration and the actual amount of remuneration paid under the arrangement must be retained for at least six years.

Soliciting Comments on Price Transparency

In the proposed rule, CMS requested comments on how to pursue its price transparency objectives in the context of the physician self-referral law. The agency notes that it is specifically interested in comments regarding the availability of pricing information and out-of-pocket costs to patients, the appropriate timing for the dissemination of pricing information and the burden associated with compliance with a requirement to provide information about factors that may affect the cost of services for which a patient is referred. CMS also seeks comments regarding whether the inclusion of a price transparency requirement in a value-based exception would provide additional patient protections against abuse.

Improving EHR and Cybersecurity Systems

CMS attempts to address several concerns surrounding arrangements between physicians and other health care providers that involve the donation of EHR and cybersecurity technology.

The agency’s proposal revises the existing EHR exception and creates a new exception for the donation of cybersecurity technology. By providing improved flexibility for these arrangements, CMS hopes to continue to foster EHR adoption and protect against cyberattacks in the health care industry.

  • EHR Exception (42 CFR § 411.357(w)): This revised exception excludes nonmonetary remuneration consisting of EHR software, information technology or training services. CMS is proposing to update the rule’s requirements relating to interoperability and data lock-in; remove the sunset provision and modify certain definitions. CMS is also considering modifying or eliminating the current requirement that recipients of EHR technology contribute at least 15 percent of the technology’s costs.3
  • Cybersecurity Exception (Proposed 42 CFR § 411.357(bb)): The agency is also proposing to create a new exception for the donation of cybersecurity technology and related services. CMS proposes to require that any donated cybersecurity technology and services must be documented in writing and be necessary and used predominantly to implement, maintain or reestablish cybersecurity. Such donations cannot be conditioned on or take into account the volume or value of referrals generated between the parties.4 CMS is also soliciting comments for an alternative proposal that would allow donations of cybersecurity hardware to occur if a cybersecurity risk assessment (conducted by both the recipient and the donor) has established that the hardware is reasonably necessary to protect both the donor and the recipient.5

Other Proposals

CMS also proposes a number of new rules and clarifications to existing rules meant to ease the “undue impact and burden” of the Stark Law.6 These proposals include:

  • A new definition of “commercially reasonable,” (42 CFR § 411.351) which turns on whether a particular arrangement furthers a legitimate business purpose of the parties and is on similar terms and conditions as like arrangements. The revised definition does not require that an arrangement be profitable in order to be commercially reasonable.
  • An objective test for determining whether compensation takes into account the volume or value of referrals or the volume or value of other business generated by the physician (42 CFR § 411.354(d)(5) and (6)). In the proposed rule, compensation would be deemed to take into account the volume or value of referrals or other business generated only if the formula used to calculate the physician’s compensation includes physicians’ referrals to the entity or other business as a variable and the physician’s compensation positively correlates with the number or value of the referrals or business.
  • A revised definition of “fair market value” (42 CFR § 411.351) that eliminates the connection to the volume or value standard. CMS also proposes to modify “fair market value” to provide for a definition of general application, a definition applicable to the rental of equipment and a definition applicable to the rental of office space. As proposed, generally, “fair market value” means the value in an arm’s-length transaction with like parties and under like circumstances, of assets or services, consistent with the general market value of the subject transaction. “General market value” is defined as the price that an asset would bring as the result of bona fide bargaining by buyers and sellers who are not otherwise in a position to refer business to each other.
  • A proposal to decouple Stark Law compliance from Anti-Kickback Statute compliance. The Stark Law is a strict liability statute. The Anti-Kickback Statute has an intent requirement. Many of the Stark Law’s exceptions require compliance with the Anti-Kickback Statute, which adds an “intent” element to compliance. CMS proposes to remove these requirements and expects entities to ensure compliance with both Stark and the Anti-Kickback Statute.
  • A new proposed exception for limited remuneration to a physician (Proposed 42 CFR § 411.357(z)) for items or services actually provided by the physician where the remuneration does not exceed an aggregate of $3,500 provided that certain requirements are satisfied.

1 Modernizing and Clarifying the Physician Self-Referral Regulations (proposed Oct. 9, 2019) (to be published in the Federal Register), https://www.hhs.gov/sites/default/files/cms-stark-law-nprm.pdf.

2 Id. at 31.

3 Id. at 232, 234, 231.

4 Id. at 272.

5 Id. at 272–73.

6 Id. at 27.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Akin Gump Strauss Hauer & Feld LLP | Attorney Advertising

Written by:

Akin Gump Strauss Hauer & Feld LLP
Contact
more
less

Akin Gump Strauss Hauer & Feld LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.