Lexology December 9, 2019
INTRODUCTION
The Centers for Medicare & Medicaid Services and the Office of Inspector General recently released notices of proposed rulemaking relating to the Stark Law and the Anti-Kickback Statute. We break down the new proposed value-based care arrangement exceptions and safe harbors, and implications for provider contracting networks such as accountable care organizations and clinically integrated networks. On October 9, 2019, in conjunction with the US Department of Health and Human Services (HHS) Regulatory Sprint to Coordinated Care initiative, the Centers for Medicare & Medicaid Services (CMS) and the HHS Office of Inspector General (OIG) both released notices of proposed rulemaking relating to the federal physician self-referral statute (42 USC § 1395nn) and its associated regulations (42 CFR § 411.350...
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