Lexology December 30, 2025
On December 1, 2025, the Centers for Medicare & Medicaid Services (“CMS”) published its annual update to the Designated Health Services (DHS) code list (“DHS List”). A 30-day comment period for the update is open until December 31, 2025.
As in prior years, CMS’s update to the DHS List both removes and adds Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes that fit within certain categories defined as DHS under 42 C.F.R. § 411.351.
When a CPT or HCPCS code is considered DHS, the service falls within the ambit of the federal physician self-referral law (commonly called the “Stark Law”).
As a strict liability statute, compliance with the Stark Law is a key issue for any...
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