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Physician Compensation Arrangements Physicians 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

Chambliss, Bahner & Stophel, P.C.

Recent Stark Law Changes Impact Physician Group Compensation Models – Be Sure to Reexamine Compensation Before 2022

Many health care providers are generally aware that the Centers for Medicare and Medicaid Services (CMS) recently implemented major changes to the Stark Law regulations. Most of the changes are already in effect. However,...more

Roetzel & Andress

Physician Compensation and Reimbursement

Roetzel & Andress on

This week on Roetzel’s HealthLaw HotSpot, Roetzel attorneys Ericka Adler and David Hochman are joined by Lucy Zielinski, Managing Partner at Lumina Health Partners, for a discussion on the changing landscape of physician...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

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

Burr & Forman

Proposed Stark Law Changes May Impact Physician Compensation Models

Burr & Forman on

On October 9, 2019, the Centers for Medicare and Medicaid Services (“CMS”) proposed sweeping changes to the federal Physician Self-Referral Law, commonly referred to as the Stark Law. While many of the changes reflect CMS’...more

Baker Donelson

Increased Flexibility Under the Stark Law for Signature AND Writing Requirements

Baker Donelson on

As CMS works to modernize and clarify the Physician Self-Referral (Stark) Law, the proposed rule published on October 17, 2019 includes a proposed revision that would provide greater flexibility for many nonabusive...more

Mintz - Health Care Viewpoints

HHS Proposes Sweeping Changes to AKS and Stark Law, Part 5: Proposed Changes to Key Stark Law Requirements and Numerous Stark Law...

As we previously reported, the Department of Health & Human Services (HHS) recently issued two proposed rules intended to reduce the regulatory burden associated with the Anti-Kickback Statute (AKS) and the Physician...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

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

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

Baker Donelson

CMS Advisory Opinion 2017-01 Approves Pop-up Alerts to Physicians Through Online Laboratory Portal

Baker Donelson on

A clinical laboratory has received a green light from CMS to offer pop-up notifications alerting physicians of various potential issues (Laboratory Alerts) through its web-based portal for ordering and reporting results of...more

Polsinelli

Are Changes to the Stark Law on the Way?

Polsinelli on

Congress has acknowledged that the Stark law is standing in the way of the healthcare industry's transition to alternative, value-based payment models, and in turn, meaningful reform may soon be on the horizon. Last...more

McDermott Will & Emery

CMS’s Final Medicaid Rule Tweaks the Proposed Rules Related to Marketing, Physician Incentive Arrangements and Long-term Care

McDermott Will & Emery on

On April 25, 2016, the Centers for Medicare & Medicaid Services (CMS), released the Medicaid managed care final rule entitled, “Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid Managed Care, CHIP...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

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

McDermott Will & Emery

CMS Proposes Stark Law Amendments, Requests Comments on Whether Stark Law Is Barrier to Health Care Reform

McDermott Will & Emery on

On July 8, 2015, the Centers for Medicare & Medicaid Services (CMS) published a notice of proposed rulemaking to amend its regulations implementing and interpreting the Stark Law (the Proposed Rule). 80 Fed. Reg. 41,686,...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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