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Compliance Perspectives: Changes to the Physician Self-Referral and Anti-Kickback Rules
Anti Kickback and Stark Law Enforcement and Compliance Issues
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
• 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
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
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
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
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
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