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CMS Settles Record Number of Stark Self-Disclosures

The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2021 and 2022 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law...more

End of COVID-19 Emergency: Legal Implications for Healthcare Providers

On Jan. 30, 2023, President Joe Biden announced that the COVID-19 public health emergency (PHE) will end May 11, 2023. Under the PHE, the federal government implemented a range of modifications and waivers impacting Medicare,...more

Stark Law 2020 Settlements Return to Pre-2019 Trend

The Centers for Medicare & Medicaid Services (CMS) recently announced 2020 settlements concerning past violation or potential violations of the physician self-referral law (the Stark Law) and the number and value of such...more

COVID-19 – New Regulatory Flexibilities for Durable Medical Equipment Suppliers

On April 29, 2020, the Centers for Medicare & Medicaid Services (CMS) updated its guidance regarding several emergency waivers related to Medicare and Medicaid policy and regulatory revisions, which were originally issued on...more

CMS Issues Explanatory Guidance on Stark Law Blanket Waivers During COVID-19 Pandemic

On April 21, 2020, the Centers for Medicare & Medicaid Services (CMS) issued guidance on the scope and application of the blanket waivers to the Physician Self-Referral Law (Stark Law) issued by the Department of Health and...more

COVID-19: Consolidated Medicare Telehealth Expansion Update

On March 31, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule with comment period (IFC). This alert is part of a series of alerts discussing the IFC provisions and comprehensive actions...more

OIG Follows the Stark Law COVID-19 Waivers for Anti-Kickback Statute

On April 3, 2020, the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS) issued a policy statement announcing that the OIG will exercise its enforcement discretion not to impose...more

Emergency Declaration Waivers, Interim Rule for Medicare Home Health and Hospice Providers Amid COVID-19

On March 31, 2020, the Centers for Medicare & Medicaid Services (CMS) issued an interim final rule with comment period (IFC). This alert is part of a series of alerts discussing the IFC provisions and comprehensive actions...more

Stark Law Waivers Issued During COVID-19 Pandemic

On March 30, 2020, Department of Health and Human Services Secretary Alex Azar issued blanket waivers to permit certain financial relationships and referrals that would otherwise be sanctioned by the Physician Self-Referral...more

ASCs’ Response to COVID-19: Nine Things to Consider

Recommendations by the Centers for Medicare & Medicaid Services (CMS) to postpone non-essential medical, surgical and dental procedures as well as state guidance on elective procedures create economic and legal challenges as...more

covid 19 stimulus bill key provisions related to home health and hospice providers

On March 25, 2020, the U.S. Senate passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) with a 96-0 vote. Thereafter, on March 27, 2020, the U.S. House of Representatives passed the CARES Act (H.R. 478),...more

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