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What to Expect, Part III: Modified AKS Safe Harbor for Personal Services & Management Contracts

The Office of Inspector General’s (“OIG”) new Anti-Kickback Statute (“AKS”) regulations modify the safe harbor for personal services and management contracts (42 CFR § 1001.952(d)) in a manner that allows providers...more

What to Expect, Part II: New Stark Law Definitions for Physician Compensation

The Centers for Medicare & Medicaid Services’ (“CMS”) new final rule amending the implementing regulations of the Physician Self-Referral Law (“Stark Law”), in part, defines fundamental terms, such as “fair market value” and...more

Leasing Residence Halls to Municipalities and Hospitals for COVID-19 Relief

The spread of COVID-19 in the United States is causing hospital administrators and government officials to call upon their local colleges and universities to house surge patients and quarantine first responders. The Harvard...more

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