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Centers for Medicare & Medicaid Services (CMS) › Fair Market Value › Compliance

Paul Hastings LLP

CMS Proposes Major ASP Reporting Overhaul — Implications for Fair Market Value and Bona Fide Service Fees

Paul Hastings LLP on

The Centers for Medicare & Medicaid Services (CMS) recently published its Proposed 2026 Physician Fee Schedule Rule (Proposed Rule), with extensive implications for drug pricing, Average Sales Price (ASP) calculations, and...more

Health Care Compliance Association (HCCA)

Defensibility of a fair market value analysis

Health Care Compliance Association (HCCA) on

Fair market value (FMV) is a pinnacle issue with respect to healthcare regulatory compliance and compensation agreements. This article will analyze the issues related to an FMV defensibility analysis of compensation...more

ArentFox Schiff

Stark Law Fair Market Value Compensation Exception Expanded to Cover Office Space and Equipment Leases and Clarifies Writing...

ArentFox Schiff on

In its first significant Stark Law rulemaking since 2015, the Centers for Medicare and Medicaid Services (CMS) recently issued a new final rule (Final Rule) intending to provide physicians and designated health services (DHS)...more

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