Lexology October 11, 2019
On October 9, 2019, the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) took the next step in their Regulatory Sprint to Coordinated Care by publishing advance copies of companion proposed rules that present significant changes to the regulatory framework of the federal physician self-referral law (commonly referred to as the “Stark Law”), the federal health care program’s Anti-Kickback Statute, and the civil monetary penalties (“CMP”) law regarding beneficiary inducements.
By way of background, the Regulatory Sprint to Coordinated Care reflects ongoing efforts by HHS to accelerate the transition to a value-based health care system focused on care coordination. About two years ago, HHS expressed an intent...
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