In late November, the Centers for Medicare and Medicaid Services and the Office of the Inspector General released their final rules revising the Physician Self-Referral Law (the “Stark Law”) and the Anti-Kickback Statute. The...more
The Centers for Medicare and Medicaid Services (“CMS”) has issued additional waivers allowing for increased flexibility during the COVID-19 public health emergency (“COVID-19 Emergency”). Of particular importance is CMS’...more
On March 28, 2020, in connection with the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Centers for Medicare & Medicaid Services (CMS) announced an expansion of its accelerated and advance...more
On December 28, 2017, the Centers for Medicare and Medicaid Services (CMS) issued a Survey and Certification Memorandum (S&C Memo) to clarify CMS’ position that it prohibits physicians and health care providers from texting...more
When Congress enacted the Bi-Partisan Budget Act of 2015 (the Act) on November 2, 2015, Section 603 of the Act effectively halted the development of any new off-campus hospital outpatient departments, also referred to as...more
One element of the Affordable Care Act (ACA), enacted in March 2010, requires providers to identify, report and return Medicare overpayments. A provider’s failure to do so can result in False Claims Act liability, Civil...more
On October 30, 2015, the Centers for Medicare and Medicaid Services (CMS) issued a final rule, to be effective January 1, 2016, which added two new exceptions and made numerous clarifications to the Stark regulations....more