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The Return of Subregulatory Guidance Reliance

Subregulatory guidance plays an important role in providing direction and insight into complex regulatory rules. Heavily regulated industries, such as the healthcare industry, are well-versed in subregulatory guidance. It may...more

Murky Waters – The Stark Controversy in Hospital-Physician Relationships

Since the completion of this article, CMS has announced that its final Stark law rule will be published in the Federal Register on December 2, 2020. I. Introduction - The Stark Law has been litigated for the past two...more

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