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Arms Length Transactions Physicians

Seyfarth Shaw LLP

CMS’ Proposed Stark Rule Change and Guidance on “The Big Three”: Fair Market Value, Commercial Reasonableness, and Taking Into...

Seyfarth Shaw LLP on

As part of a larger “Regulatory Sprint to Coordinated Care” the Centers for Medicare & Medicaid Services (CMS) of the U.S. Department of Health & Human Services (HHS) recently issued a proposed rule aimed at modernizing and...more

Jones Day

CMS Proposes Changes to Arrangement Valuation Terms Under the Federal Stark Law

Jones Day on

The Situation: There has been longstanding uncertainty in the health care industry related to interpreting certain compensation valuation terms used throughout the statutory and regulatory exceptions to the federal physician...more

Foley & Lardner LLP

Loan or Other Financial Obligation Forgiveness– A Continuing Fraud and Abuse Challenge

Foley & Lardner LLP on

There are many health care financial arrangements where one entity has a financial obligation to another, with whom it either does business directly, or to which it makes referrals, and that obligation is either past due or...more

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