On November 20, 2020, CMS and the OIG published their much anticipated amendments to the federal Stark and Anti-Kickback laws. As summarized in our recent client alert, the changes open the door to value-based contracting with potential referral sources. They also modify existing regulations and create new safe harbors applicable to provider relationships.
To assist our clients and friends, Holland & Hart has prepared a redline version of the regulations that highlight the changes. The documents may be accessed here:
The Federal Register versions of the revised regulations and accompanying commentary may be accessed here: