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Physician Group Practice Alert: New Stark Requirements on Compensation Models Take Effect January 1, 2022

On December 2, 2020, the Centers for Medicare & Medicaid Services (CMS) published the final "Sprint Regulations," reinterpreting key aspects of the federal physician self-referral or "Stark" law. Most of the Sprint...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

2021 OPPS and ASC Payment System Final Rule: Change Is the Only Constant

On December 2, 2020, the Centers for Medicare & Medicaid Services (CMS) released the calendar year 2021 Final Rule implementing changes to the Medicare hospital Outpatient Prospective Payment System (OPPS) and Ambulatory...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

Recent Stark Developments: A Moving Target Where a Miss is as Good as a Mile

The federal physician self-referral ban or Stark law has been a part of the legal landscape for almost 25 years. The breadth of the law’s prohibitions, its strict liability formulation and draconian remedies have made it the...more

OIG Fraud Alert: Physicians in the Cross Hairs

On June 9, 2015, the Department of Health and Human Services Office of Inspector General (OIG) issued a Fraud Alert focused on physician relationships. The Alert cautions physicians who enter into compensation arrangements...more

The SGR Fix: Congress Charts a New Course for Physician Payments and Gainsharing

On April 16, President Obama signed into law the “Medicare Access and CHIP Reauthorization Act of 2015,” (“MACRA”) which repealed the Sustainable Growth Rate (“SGR”) payment formula used to limit annual updates to Medicare...more

Sometimes the Government is Here to Help: OIG Proposes More Flexibility in Rules Governing Local Transportation, Beneficiary...

The U.S. Department of Health & Human Services, Office of Inspector General ("OIG") just released a proposed rule (“Proposed Rule”) that provides long awaited guidance on patient transportation services, relaxes the...more

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