Lexology October 30, 2019
This Client Alert serves as the third in a three-part series in which we describe and analyze the rules proposed by the Department of Health and Human Services (“HHS”) Centers for Medicare & Medicaid Services (“CMS”) as part of its “Regulatory Sprint to Coordinated Care.”
On October 17, 2019, the HHS Office of Inspector General (“OIG”) and CMS published in the Federal Register companion proposed rules that present significant changes to the regulatory framework of the federal health care program’s Anti-Kickback Statute (“AKS”), the civil monetary penalties (“CMP”) law, and the federal physician self-referral law (commonly referred to as the “Stark Law”). Unless an extension is granted, public comments must be delivered to the agencies by 5 p.m. (EST) on...