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Time, Gravity, and the Complexity of Stark: 2022 MPFS Stark Proposals

There are three things that cannot be stopped: time, gravity, and the increasing complexity of the Stark Law. To be fair, complexity has not been the goal of the Centers for Medicare & Medicaid Services (CMS). Rather, Stark's...more

Done Sprinting, but Are We There Yet? The Value-Based Stark Exceptions and AKS Safe Harbors

On December 2, 2020, CMS and OIG finished a two-year sprint to modernize the Stark and Anti-Kickback (AKS) regulations to remove barriers to value-based care and incentivize patient-centered care coordination....more

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