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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

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

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