Lexology October 23, 2019
On October 9, 2019, the U.S. Department of Health and Human Services Office of the Inspector General (“OIG”) and Centers for Medicaid & Medicare Services (“CMS”) released their long-awaited proposed rules describing potential changes to regulations implementing the federal anti-kickback statute (the “AKS”), beneficiary inducement provisions of the civil monetary penalty law (the “CMPL”), and the physician self-referral law (the “Stark Law”). OIG and CMS have described the changes as efforts to reduce barriers to the coordination and delivery of value-based care.
The proposed rulemakings each include three new provisions for value-based care arrangements presenting different financial risk profiles.
This is our executive summary of the proposed rules. Our detailed analysis is available here.
Proposals to Protect Certain Value-Based Care...
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