News & Analysis as of

Physician Compensation Arrangements Fair Market Value Centers for Medicare & Medicaid Services (CMS)

Nelson Mullins Riley & Scarborough LLP

Fair Market Value Defensibility Analysis: Why is It Different from a Fair Market Value Opinion?

Fair market value is a pinnacle issue for compliance under the Stark Law and Anti-Kickback Statute. Compensation arrangements that are required to be representative of fair market value under Stark/AKS include employment,...more

Steptoe & Johnson PLLC

What to Expect, Part II: New Stark Law Definitions for Physician Compensation

Steptoe & Johnson PLLC on

The Centers for Medicare & Medicaid Services’ (“CMS”) new final rule amending the implementing regulations of the Physician Self-Referral Law (“Stark Law”), in part, defines fundamental terms, such as “fair market value” and...more

Jones Day

CMS Finalizes and Clarifies Key Valuation Terms in the Stark Law

Jones Day on

The Situation: Under the federal Physician Self-Referral Law ("Stark Law"), many physician arrangements must meet one or more of the so-called "big three" requirements: that the arrangement be "commercially reasonable," that...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

Mintz - Health Care Viewpoints

Skeletons in the Closet? Beware of Potential Enforcement Actions

With Halloween looming, a discussion of skeletons that may be lurking in a health care provider’s closet is timely. Many of our previous posts, as well as the monthly Qui Tam Updates published by our Health Care Enforcement...more

McDermott Will & Emery

Huge Stark Law Hospital Settlements and Physician Culpability - The New Normal Post-Tuomey?

McDermott Will & Emery on

After the federal government’s victory against Tuomey Hospital, we have seen an increasing number of large False Claims Act (FCA) settlements with hospitals involving Stark Law allegations. Relators are even citing, as...more

Seyfarth Shaw LLP

Increased OIG Scrutiny on Medical Directorships

Seyfarth Shaw LLP on

On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) released a Fraud Alert entitled, "Physician Compensation Arrangements May Result in Significant Liability." The Alert is an...more

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