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Ownership Transparency: The New Normal in Healthcare?

On November 17, 2023, the U.S. Department of Health and Human Services ("HHS") Centers for Medicare and Medicaid Services ("CMS") published a final rule (the "Final Rule") requiring Medicare skilled nursing facilities...more

Time, Gravity, and the Complexity of Stark: 2022 MPFS Stark Proposals

There are three things that cannot be stopped: time, gravity, and the increasing complexity of the Stark Law. To be fair, complexity has not been the goal of the Centers for Medicare & Medicaid Services (CMS). Rather, Stark's...more

CMS Sprints to Overhaul Stark

With the benefit of more than three decades of rulemaking and hundreds of submissions under the Self-Referral Disclosure Protocol, CMS has seized the opportunity in the final Sprint Regulations to adopt a number of...more

The Other Half of the Stark Sprint Regulations - Valuable (but Not Value-Based) Proposals

The Sprint Regulations’ value-based exceptions and related amendments have attracted much well-deserved attention. However, value-based matters aside, the Sprint Regulations portend significant positive changes to the Stark...more

New Washington Law Requires Advance Notice to the Attorney General for Certain Healthcare Transactions

Starting January 1, 2020, hospitals, health systems, and many other healthcare providers must give notice to the Attorney General 60 days in advance of closing certain transactions. ...more

New Year, New Possibilities: OIG Final Rule Amends Beneficiary Inducement Rules

The Office of Inspector General (“OIG”) of the Department of Health and Human Services has issued a final rule (“Final Rule”) adding new safe harbors to the federal anti-kickback statute, amending existing safe harbors, and...more

Tick, Tock, Shock: CMS Provides Welcome Guidance in the Final Regulation for 60-Day Rule

On Feb. 12, 2016, CMS published the much anticipated final regulations implementing the so-called “60-Day Rule.” Congress adopted the 60-Day Rule as part of the Affordable Care Act (ACA). The Rule requires health care...more

[Event] Preparing for the Comprehensive Care Joint Replacement Program - Jan. 5th, 6th, & 7th - Seattle, Portland, Los Angeles

Please join Davis Wright Tremaine partners Bob Homchick and Adam Romney, and associate Kyle Gotchy for a briefing regarding the final rule for the Comprehensive Care Joint Replacement (CJR) Program. They will discuss the...more

Compliance Guidelines for Governing Boards: Some Further Thoughts and Comments

On April 20, 2015, four organizations (including OIG, American Health Lawyers Association, the Association of Healthcare Internal Auditors and the Health Care Compliance Association) issued “Practical Guidance for Health Care...more

OIG Issues Board Guidance on Compliance Oversight

On April 20, 2015, the Inspector General of the Department of Health and Human Services (OIG), the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA) and the Health Care...more

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