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Stark Law Group Practice Requirements

The Centers for Medicare & Medicaid Services (CMS) published updates to the CMS Voluntary Self-Referral Disclosure Protocol (SRDP) on January 23, 2023. The SRPD is the CMS process for Medicare providers and suppliers to...more

No Surprises Act Updates – New Final Rule, CMS Resources and New FAQs

On August 19, 2022, the United States Department of Health and Human Services, Department of Labor, and Department of the Treasury (the Departments) published a new final rule (Final Rule) under the federal No Surprises Act,...more

Health Care Price Transparency Update – New Rules and Recent Enforcement

Enforcement of the Transparency in Coverage Final Rule’s (Coverage Rule) cost disclosure requirement for health plans and health insurance issuers will begin effective July 1, 2022. The Coverage Rule was issued in January...more

The Accelerating Movement Towards Hospital Care in the Home Setting

The next time you step into an emergency room, you may learn the hospital can provide you with hospital-level services to treat your illness in your home. Until recently, the idea of hospitals providing services to patients...more

HHS Issues New Value-Based Care Exceptions and Safe Harbors to Stark Law and Anti-Kickback Statute

On November 20, 2020, the Department of Health and Human Services (HHS), Office of Inspector General (OIG) and the Centers for Medicare & Medicaid Services (CMS) issued final rules modifying regulations for the Physician...more

Preparing for Increased Nursing Survey Facility Activity Related to COVID-19 and Infection Control

As of July 12, there have been 142,231 confirmed COVID-19 cases and 38,518 deaths in nursing homes. For this reason, CMS recently called nursing homes “ground zero for COVID-19” and announced enhanced survey activities and...more

CMS Directs Increased Nursing Facility Survey Activity and Penalties Related to COVID-19 and Infectious Control

As the COVID-19 pandemic began this spring, the Centers for Medicare and Medicaid Services (CMS) called on all health care providers to activate infection control practices to help limit the spread of the virus....more

CMS Issues Blanket Waivers of the Stark Law in Response to COVID-19 Emergency

In response to the COVID-19 pandemic, on March 30, 2020, Centers for Medicare & Medicaid Services (“CMS”) issued blanket waivers of sanctions under Section 1877 of the Social Security Act (the “Stark Law”). The waivers are...more

CMS Issues Proposed Rule to “Modernize and Clarify” the Stark Law

On October 9, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a Proposed Rule to “modernize and clarify” the federal physician self-referral law (the “Stark Law”). The Proposed Rule was issued in conjunction...more

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