News & Analysis as of

Stark Law Request For Information

Baker Donelson

Volume Value Take 2

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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

Dorsey & Whitney LLP

CMS Finalizes Changes to the Stark Advisory Opinion Regulations; 2020 DHS Code List and CPI-U Updates

Dorsey & Whitney LLP on

In the calendar year 2020 Medicare physician fee schedule final rule (“PFS”), which was published in the Federal Register on November 15, 2019 (available here), CMS finalized changes to the advisory opinion process under the...more

Epstein Becker & Green

HHS’s Regulatory Sprint to Coordinated Care – Part 3: CMS Proposes Expansive Set of Changes to Stark Regulations

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This Client Alert serves as the third in a three-part series in which we describe and analyze the rules proposed by the Department of Health and Human Services (“HHS”) Centers for Medicare & Medicaid Services (“CMS”) as part...more

Epstein Becker & Green

HHS’s Regulatory Sprint to Coordinated Care – Part 1: CMS and OIG Issue Long-Awaited Proposed Rules

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On October 9, 2019, the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) took the next step in their Regulatory Sprint to Coordinated...more

Bass, Berry & Sims PLC

Key Takeaways from CMS' New Proposed Rule on Stark Law Advisory Opinions

While the industry awaits more sweeping value-based related changes to the Stark Law regulations, on July 29, 2019, the Centers for Medicare & Medicaid Services (CMS) took a small step toward updating its Stark Law advisory...more

Foley & Lardner LLP

2019 Health Care Industry Outlook

Foley & Lardner LLP on

A new wave of change is poised to disrupt the way health care is delivered in the United States. This time around, the disruption is coming not from lawmakers or the president, who have struggled to repeal or improve upon...more

Bricker Graydon LLP

HHS regulatory sprint to coordinated care: Will meaningful changes make it across the finish line?

Bricker Graydon LLP on

As part of the U.S. Department of Health and Human Services (HHS) initiative known as the “Regulatory Sprint to Coordinated Care” in 2018, HHS asked industry stakeholders for information regarding how it can improve both the...more

Mintz - Health Care Viewpoints

HHS Continues the “Sprint to Coordinated Care”

On August 27, 2018, the Office of the Inspector General (OIG) of the Department of Health and Human Services (HHS) issued a request for information (RFI) seeking comment on the anti-kickback statute (AKS) and the beneficiary...more

Chambliss, Bahner & Stophel, P.C.

The Office of Inspector General's New Request for Information

Feedback Sought Regarding the Anti-Kickback Statute and the Civil Monetary Penalties Law - The Department of Health and Human Services ("HHS") Office of Inspector General ("OIG") issued a request for information ("RFI")...more

Bass, Berry & Sims PLC

Sprinting to Coordinated Care: Healthcare Industry Urges Stark Law Relief as OIG Solicits Feedback on Changes to the Anti-Kickback...

August 24, 2018 marked a busy day for the U.S. Department of Health & Human Services' (HHS) self-designated "Regulatory Sprint to Coordinated Care," an initiative aimed at dismantling the regulatory barriers to providers...more

Epstein Becker & Green

Response to RFIs: EBG Submits Comments to CMS on Stark Law Reforms and Is Preparing Comments to OIG on Anti-Kickback Statute and...

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As addressed in a previous Epstein Becker Green (“EBG”) Client Alert, earlier this summer, the Centers for Medicare & Medicaid Services (“CMS”) published in the Federal Register a “request for information” (“RFI”) regarding...more

Holland & Knight LLP

Request for Information: Aligning AKS and CMP with Coordinated Care Initiatives

Holland & Knight LLP on

On Aug. 24, 2018, the Office of Inspector General (OIG) issued a request for information (RFI) regarding the Anti-Kickback Statute (AKS) and Beneficiary Inducement provisions of the Civil Monetary Penalty (CMP) law. The...more

Hogan Lovells

HHS watchdog eyes anti kickback safe harbors for care coordination beneficiary incentives and cost sharing

Hogan Lovells on

On Monday, the Department of Health and Human Services (HHS) Office of the Inspector General (OIG) published a wide-ranging request for information (RFI) seeking ideas on how it might add or modify safe harbors to the...more

Bass, Berry & Sims PLC

Stark Under the Microscope: Congress and HHS Examine Reform of the Stark Law for a Value-Based System

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On July 17, 2018, the U.S. House of Representatives' Ways and Means Committee Subcommittee on Health ("Subcommittee") expressed its commitment to modernizing the Stark Law during a hearing in which industry and government...more

Dorsey & Whitney LLP

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

Dorsey & Whitney LLP on

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

Chambliss, Bahner & Stophel, P.C.

CMS Request for Information – Stark Law

CMS is seeking input on ways to reduce the regulatory burdens of the physician self-referral law (commonly known as the Stark Law), particularly as it relates to the ongoing effort to transition from a fee-for-service to a...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

Cooley LLP

Blog: CMS Requests Information Regarding The Stark Law’s Potential Barriers to Coordinated Care

Cooley LLP on

On June 25, 2018, the Centers for Medicare and Medicaid Services (“CMS”) published a Request for Information (“RFI”) in the Federal Register regarding section 1877 of the Social Security Act, also known as the “physician...more

Morgan Lewis

Is Stark Law Reform or Repeal in the Offing?

Morgan Lewis on

The Centers for Medicare & Medicare Services has issued a request for information seeking public comment on how to address the undue regulatory impact and burden of the physician self-referral law, commonly known as the Stark...more

Holland & Knight LLP

CMS Seeks Stakeholder Input on Easing Stark Law Requirements

Holland & Knight LLP on

• In order to encourage value-based reimbursement and care delivery, the Centers for Medicare & Medicaid Services (CMS) has published a Request for Information (RFI) seeking public input on how to address any undue regulatory...more

King & Spalding

CMS Seeking Public Comment on Stark Law Burdens

King & Spalding on

The Centers for Medicare and Medicaid Services (CMS) is seeking public comment on the burdens imposed by the Stark Law. Specifically, on June 25, 2018, CMS published in the Federal Register a Request for Information (RFI) on...more

Epstein Becker & Green

CMS Request for Information: Reforming the Stark Law to Facilitate the Transformation to Value-Based Care

Epstein Becker & Green on

On June 25, the Centers for Medicare and Medicaid Services (“CMS”) published in the Federal Register a “request for information” regarding potential reforms to the federal physician self-referral law (or the “Stark Law”). ...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

Polsinelli

CMS “Goes Fishing” on Stark Law’s Impediments to Value-Based, Coordinated Care

Polsinelli on

On June 20, 2018, the Centers for Medicare & Medicaid Services and Department of Health and Human Services issued a “request for information” (RFI) seeking input on strategies to reduce the burden of the federal physician...more

Mintz - Health Care Viewpoints

Hospitals and Others Respond to “Red Tape Relief Project” Requests

Last week, a number of health care industry associations sent letters to Congress detailing ways in which the government could relieve them of the burdens associated with “red tape.” The letters are in response to the first...more

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