On November 20, 2020, in addition to new Stark Law regulations intended to accommodate value-based financial arrangements with physicians, the Centers for Medicare and Medicaid Services (CMS) issued final regulations that...more
As part of its Regulatory Sprint to Coordinated Care, on November 20, 2020, the Department of Health and Human Services (HHS) published two final rules which make significant and sweeping changes to regulations relating to...more
Like virtually every other sector of the economy, COVID-19 has presented novel challenges to health care providers. As the pandemic has forced physicians to adapt to changing patient care demands and a drop in...more
On April 21, 2020, the Centers for Medicare and Medicaid Services (CMS) issued a brief explanatory guidance document related to the scope and application of its previous Stark Law blanket waivers to certain financial...more
On March 30, 2020, the Centers for Medicare and Medicaid Services (CMS) issued an unprecedented list of Stark Law blanket waivers under its emergency authority granted in Section 1135 of the Social Security Act (the Act)...more
More than four years after the Centers for Medicare & Medicaid Services' (CMS) issuance of the Stark Self-Referral Disclosure Protocol (SRDP), it's time to assess the results. The SRDP was designed by Congress to resolve...more