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CMS Extends Virtual Direct Supervision Through 2024

On November 2, the Centers for Medicare & Medicaid Services (CMS) extended virtual direct supervision—i.e., the ability to provide direct supervision through real-time, audio-visual technology (rather than in-person presence)...more

OIG Approves Paying Employed Physicians Profits from ASCs Operated by Employer

On October 13, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued Advisory Opinion 23-07, approving a physician practice’s proposal to pay its physician-employees a portion of the...more

OIG Offers Guidance for ASCs When Physician-Investors Fail the One-Third Income Test

Nearly 25 years ago, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) created a regulatory safe harbor to the federal Anti-Kickback Statute (AKS) for physician investment in...more

HHS-OIG Year in Review - 2022

The Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) continues to offer valuable insights to the healthcare industry as to how best to approach increasingly complex healthcare fraud...more

CMS Tweaks Voluntary Self-Referral Disclosure Protocol, Adds New Form for Group Practice Disclosures

On January 23, the Centers for Medicare & Medicaid Services (CMS) released revisions to its Voluntary Self-Referral Disclosure Protocol (SRDP), an important mechanism through which providers may disclose actual or potential...more

CMS Proposes New Stark Law Exception for Rural Emergency Hospitals

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

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