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Self-Referral Public Comment

Baker Donelson

CMS Improves Stark Advisory Opinion Process

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The Centers for Medicare & Medicaid Services (CMS) recently updated its advisory opinion regulations, codified at 42 CFR §§ 411.370 through 411.389, in a final rule issued November 15, 2019. The update liberalizes and...more

Bricker Graydon LLP

CMS and OIG propose changes to existing rules for donations of electronic health records and new rules for donations of...

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On October 9, 2019, the Office of Inspector General (OIG) released proposed changes to the regulations interpreting the federal Anti-Kickback Statute (AKS). On the same day, the Centers for Medicare and Medicaid Services...more

Bricker Graydon LLP

CMS proposes to change the way group practices can pay profit shares to physicians under Stark Law

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Part of the Centers for Medicare and Medicaid Services’ (CMS) proposed changes to the regulations interpreting the Physician Self-Referral Law (the “Stark Law”), released on October 9, 2019, include changes to the special...more

Bricker Graydon LLP

CMS proposes changes to and clarifications of key Stark Law terms

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Part of the Centers for Medicare and Medicaid Services’ (CMS) proposed changes “to modernize and clarify” regulations interpreting the Physician Self-Referral Law (the “Stark Law”), released on October 9, 2019, contain...more

Baker Donelson

CMS Proposes Liberalizing the Stark Advisory Opinion Process

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When the Centers for Medicare and Medicaid Services (CMS) sought input on ways to address the undue burdens of the Stark law through a Request for Information (RFI) in June 2018, its anticipated focus was care coordination,...more

McDermott Will & Emery

CMS Publishes Proposed Amendments to Stark Law Advisory Opinion Regulations

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On July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) published the CY 2020 Medicare Physician Fee Schedule Proposed Rule, which included substantial changes to the physician self-referral law (Stark Law)...more

Holland & Knight LLP

Healthcare Law Update: September 2018

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Regulation - CMS Contemplating Telemedicine Changes - The Centers for Medicare & Medicaid Services (CMS) recently published what it described as a "major proposed rule" that covers a number of topics that could have...more

Dorsey & Whitney LLP

Calls for Modernizing the Stark Law Continue; CMS Seeks Public Input on Stark Law Reforms

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Many regulatory and legislative calls for modernizing the federal physician self-referral law (or “Stark Law”) in light of the move to value-based payment under Medicare have been made in recent months. Most recently, a...more

Proskauer Rose LLP

CMS Issues Proposed Rule with Significant Revisions to the Medicare Physician Fee Schedule and Other Payment Policies

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On July 12, 2018, the Centers for Medicare & Medicaid Services ("CMS") issued a proposed rule that includes proposals to update payment policies and rates for services furnished under the Medicare Physician Fee Schedule...more

Robinson+Cole Health Law Diagnosis

CMS issues Request for Information on the burdens the Stark Law may Impose on Care Coordination

The Centers for Medicare and Medicaid Services (CMS) issued a Request for Information (RFI) seeking input from the public on the burden the Stark Law may impose on patient care and recommendations on how to address any undue...more

Baker Donelson

CMS Signals Willingness to Revamp Stark for Coordinated Care Efforts

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CMS issued a Request for Information (RFI), seeking input from the public on how best to address and mitigate any "undue regulatory impact and burden" of the physician self-referral law ("Stark Law"). The RFI, filed on June...more

Baker Donelson

Summary of Major Provisions in the Proposed 2017 Physician Fee Schedule

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The proposed Physician Fee Schedule for 2017 (PFS) includes several changes covering a litany of topics spanning from telehealth services to expanding the Diabetes Prevention Program Model. The following is a high-level...more

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