News & Analysis as of

Self-Referral Stark Law

Dentons

Ep. 30 – Ensuring Payments to Physicians for Administrative Services Meet a Stark Exception

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Providers will often pay physicians for serving in important administrative roles within the organization. Compensation for administrative services can create risk to the organization under multiple laws, including the...more

McGuireWoods LLP

CMS Again Settles Record Stark Self-Disclosures in 2023

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The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2023 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark...more

Gardner Law

Highlights from OIG’s New Compliance Program Guidance

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The U.S. Department of Health and Human Services Office of Inspector General (HHS OIG) released an important new compliance resource in November 2023. The HHS OIG’s new General Compliance Program Guidance (GCPG) is intended...more

McDermott Will & Emery

Stark Law Changes for 2024: CMS Updates Designated Health Services Code List

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On November 29, 2023, the Centers for Medicare & Medicaid Services (CMS) published the 2024 annual update to the designated health services (DHS) Code List. This annual update includes important changes for Medicare providers...more

The Volkov Law Group

HHS-OIG Issues Comprehensive Compliance Guidance that Underscores the Need for a Robust and Independent Compliance Function (Part...

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The health care industry has a rich history of commitment and innovation in developing effective compliance  programs.  Going back to the 1990s, HHS elevated compliance program requirements for healthcare companies. Many of...more

Bricker Graydon LLP

A Long-Awaited Change: OIG Updates its Compliance Program Guidances

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From 1998-2008, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) published compliance program guidelines for various industries in the Federal Register....more

Chambliss, Bahner & Stophel, P.C.

Client Update – New OIG General Compliance Guidance Released

November 28, 2023 | Legal Update On November 10, 2023, the Office of the Inspector General (OIG) released its widely anticipated General Compliance Program Guidance (GCPG). The OIG had previously announced that it would...more

Katten Muchin Rosenman LLP

CMS Settled a Record Number of SRDPs in 2022

The Centers for Medicare and Medicaid Services (CMS) recently updated the publicly available information regarding the Self-Referral Disclosure Protocol (SRDP) settlements to include aggregate settlement data from calendar...more

Bass, Berry & Sims PLC

CMS Publishes New Data on Self-Referral Disclosure Protocol Settlements

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The Centers for Medicare & Medicaid Services (CMS) recently published updated data regarding settlements made under the Voluntary Self-Referral Disclosure Protocol (SRDP), an important mechanism through which providers may...more

McDermott Will & Emery

Congress Adds AKS and Stark Law Exceptions for Certain Wellness Programs

As a part of the Consolidated Appropriations Act, 2023 (CAA), Congress passed new exceptions to the Physician Self-Referral Law (Stark Law) and the federal Anti-Kickback Statute (AKS) allowing certain healthcare entities to...more

Epstein Becker & Green

Hidden in Plain Sight: Lesser-Known Exceptions Recently Adopted by Congress to the Federal Physician Self-Referral Law and...

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At the end of 2022, Congress enacted the Consolidated Appropriations Act of 2023 (“CAA”), for which there has been much fanfare.   As it relates to health care, this legislation included provisions addressing issues such...more

McDermott Will & Emery

Special Report - Medicare Providers Take Note: CMS Streamlines the Stark Law Voluntary Self- Referral Disclosure Protocol, Updates...

McDermott Will & Emery on

In the last few months, the US Centers for Medicare & Medicaid Services (CMS) has made several noteworthy changes and provided a material clarification for providers and suppliers who are subject to the federal physician...more

Robinson+Cole Health Law Diagnosis

Stark Settlement Targeting Hospital and Physicians a Reminder for Health Care Organizations

On March 29, 2023, the Department of Justice’s (DOJ) Office for the Eastern District of Michigan announced a notable set of three settlements (collectively, the Settlement) in excess of $69 million dollars total with a...more

McDermott Will & Emery

Healthcare Regulatory Check-up Newsletter | January 2023 Recap

This issue of McDermott’s Healthcare Regulatory Check-Up highlights significant regulatory activity and developments occurring in January 2023, including several criminal and civil enforcement actions related to the federal...more

McGuireWoods LLP

CMS Streamlines Stark Law Self-Disclosures

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The Centers for Medicare & Medicaid Services recently announced updates to the voluntary self-referral disclosure protocol (SRDP), including revisions to streamline SRDP submissions. Providers and suppliers may report and...more

Baker Donelson

CMS Approves New Group Information Form under Self-Referral Disclosure Protocol

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Following the comment period that ended on August 8, 2022, the Centers for Medicare and Medicaid Services (CMS) recently finalized changes to the Self-Referral Disclosure Protocol (SRDP) for physician practices to disclose...more

Maynard Nexsen

Stark Law Group Practice Requirements

Maynard Nexsen on

The Centers for Medicare & Medicaid Services (CMS) published updates to the CMS Voluntary Self-Referral Disclosure Protocol (SRDP) on January 23, 2023. The SRPD is the CMS process for Medicare providers and suppliers to...more

Mintz - Health Care Viewpoints

New Group Practice Information Form for the Stark Law’s Self-Referral Disclosure Protocol

Effective March 1, 2023, the Stark Law’s Self-Referral Disclosure Protocol (SRDP) will include a new Group Practice Information Form for physician practices to report noncompliance arising from a failure to fully satisfy the...more

Foley & Lardner LLP

Stark Law Changes: Hospitals Need to Revisit Physician Compensation Arrangements

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Based on recent changes and clarifications made by the Centers for Medicare and Medicaid Services (CMS) in the Federal Physician Self-Referral Law (commonly known as the “Stark Law”), hospitals and health systems need to...more

Dickinson Wright

[Webinar] Safeguarding Your Practice: 2022 Fraud and Abuse Updates - November 10th, 1:00 pm - 2:00 pm EST

Dickinson Wright on

This presentation will provide an update on significant changes in significant cases related to the Stark Law, Civil Monetary Penalties Law, and the Anti-Kickback Statute....more

Baker Donelson

CMS Requests Comments on Proposed Changes to Stark Law Self-Referral Disclosure Protocol Forms

Baker Donelson on

On June 9, 2022, the Centers for Medicare and Medicaid Services (CMS) solicited comments to proposed changes to the Self-Referral Disclosure Protocol (SRDP) for physician practices disclosing group practice noncompliance....more

Bass, Berry & Sims PLC

CMS Proposes New Stark Law Exception for Rural Emergency Hospitals

Bass, Berry & Sims PLC on

On July 15, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgery Center (ASC) Payment System proposed rule...more

McGuireWoods LLP

CMS Considers Streamlined Physician Group Stark Law Self-Disclosures

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On June 9, 2022, the Centers for Medicare & Medicaid Services announced an opportunity for the public to comment through Aug. 8, 2022, on its voluntary self-referral disclosure protocol (SRDP). The voluntary SRDP is a way to...more

Benesch

CMS Clarifies Expansion of Physician-Owned Hospital’s “Unlicensed” Observation Beds Under Stark “Whole Hospital” Exception

Benesch on

The Centers for Medicare & Medicaid Services (CMS) recently issued an advisory opinion under the federal physician-self referral law (the “Stark Law”) (Advisory Opinion No. CMS-AO-2021-2) (the “Advisory Opinion”) clarifying...more

Goodwin

Changes to Stark Law Special Compensation Rules for Group Practices Go into Effect on January 1, 2022

Goodwin on

The final rules regarding special compensation under 42 U.S.C. § 1395nn, the Physician Self-Referral or Stark Law, go into effect on January 1, 2022 and will require many physician group practices to modify their compensation...more

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