The law firm of Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C., sincerely appreciates the opportunity to comment upon the proposed clarifications and changes to the Stark regulations issued by the Centers and Medicare and Medicaid Services (CMS) at 80 Fed. Reg. 41686, 41909 (July 15, 2015). The numbering of the sections and subsections below corresponds to those in the proposed rulemaking and the Federal Register pages on which each item begins are indicated.