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Physician Compensation Arrangements Hospitals Centers for Medicare & Medicaid Services (CMS)

Health Care Compliance Association (HCCA)

[Event] 2023 Healthcare Enforcement Compliance Conference - November 5th - 7th, Washington, DC

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us at HCCA’s Annual Healthcare Enforcement Compliance Conference to...more

Health Care Compliance Association (HCCA)

[Virtual Event] Healthcare Enforcement Compliance Conference - November 7th - 9th, 8:55 am - 3:30 pm CST

Hear directly from the enforcement community - Want to gain insight into properly monitoring, detecting, investigating, and managing violations? Join us virtually at HCCA’s Annual Healthcare Enforcement Compliance...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

Nelson Mullins Riley & Scarborough LLP

Murky Waters – The Stark Controversy in Hospital-Physician Relationships

Since the completion of this article, CMS has announced that its final Stark law rule will be published in the Federal Register on December 2, 2020. I. Introduction - The Stark Law has been litigated for the past two...more

Holland & Hart - Health Law Blog

wRVU Compensation Formulas: Time to Review

Many hospitals, physician groups, or other providers compensate employed or contracted practitioners based on the work relative value units (“wRVUs”) they generate, e.g., a physician may be paid $x per wRVU performed....more

Baker Donelson

Volume Value Take 2

Baker Donelson on

The CMS proposed regulation issued on October 17, 20191 provides much needed clarity on the question of when compensation is deemed to vary with the volume or value of referrals or other business generated between the...more

Bass, Berry & Sims PLC

Third Circuit Holds Allegations of Improper Compensation Methodologies under the Stark Law Survive Motion to Dismiss

Bass, Berry & Sims PLC on

The U.S. Court of Appeals for the Third Circuit recently issued a False Claims Act (FCA) decision calling into question productivity-based physician compensation structures under the Stark Law, in reliance on a controversial...more

Morgan Lewis

Stark Law Clarifications Bring Both Benefits and Potential Challenges - Hospital Industry Viewpoint

Morgan Lewis on

The new clarifications suggest a more lenient CMS, but providers shouldn’t compromise their compliance standards. Throughout the halls of hospitals’ legal and compliance departments, people have been talking....more

McCarter & English, LLP

Don’t Mail That Overpayment Disclosure Just Yet: Implications of CMS’ Final Rule Expanding the Writing, Signature and Holdover...

The Centers for Medicare and Medicaid Services (CMS) on Nov. 16, 20151 published the calendar year 2016 physician fee schedule final rule, fundamentally reducing the burden on entities seeking to demonstrate compliance with...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

Manatt, Phelps & Phillips, LLP

Health Update - September 2015

Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more

Poyner Spruill LLP

Proposed Changes to Stark Rule Would Create New Hospital Exceptions and Lessen Burden of Self-Disclosures

Poyner Spruill LLP on

In a development that is limited in scope but still welcomed by hospitals, the proposed 2016 Physician Fee Schedule proposes a number of new exceptions to the physician self-referral or Stark law and other refinements that...more

Arnall Golden Gregory LLP

CMS Proposes Amendments to Stark Law

On July 15, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published proposed regulations governing policies and payments made under the 2016 Physician Fee Schedule (the Proposed Rule). Notably, the Proposed Rule...more

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