Lexology December 27, 2023
On November 29, 2023, the Centers for Medicare & Medicaid Services (CMS) published the 2024 annual update to the designated health services (DHS) Code List. This annual update includes important changes for Medicare providers who rely on the Code List to ensure financial relationships with physicians remain in compliance with the federal physician self-referral law (the Stark Law). Of particular note, CMS has clarified that certain definitive drug testing codes will be considered DHS.
In Depth
BACKGROUND
The Stark Law restricts financial relationships between a physician and any entity that furnishes and bills Medicare for DHS (a DHS Entity), and many of the most commonly used Stark Law exceptions implicitly rely on DHS Entities to appropriately identify the DHS such...
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