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Sidley Austin LLP | USA | 9 Dec 2021

Recent Settlement Illustrates Enforcement Risks Associated With Physician Roll-Ups

On December 2, 2021, the Department of Justice (“DOJ”) issued a press release announcing that Flower Mound Hospital Partners (“Flower Mound”), a…
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K&L Gates LLP | USA | 4 Feb 2021

White Paper: Value-Based Safe Harbors and Exceptions to the Anti-Kickback Statute and Stark Law

On 2 December 2020, the U.S. Department of Health and Human Services’ (HHS) issued two Final Rules in conjunction with its “Regulatory Sprint to…
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Hogan Lovells | USA | 1 Dec 2020

HHS Regulatory Sprint takes final shape: Part 1: Substantial Stark Law regulatory revisions adopted

Along with proposed Stark Law exceptions designed to accommodate value-based care models, the Centers for Medicare & Medicaid Services (CMS or the…
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Hogan Lovells | USA | 1 Dec 2020

HHS Regulatory Sprint takes final shape, Part 2: AKS, Stark regulatory revisions for value-based care

Following on last October’s publication of two proposed rules, the Department of Health and Human Services (HHS) published on November 20 two final…
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Bass Berry & Sims PLC | USA | 15 Jul 2020

Eighth Circuit Affirms Dismissal of Kickback Case

On June 25, the U.S. Court of Appeals for the Eighth Circuit affirmed the dismissal with prejudice of a qui tam False Claims Act (FCA) suit alleging…
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Thompson Hine LLP | USA | 3 Apr 2020

CMS Issues Blanket Waivers of the Stark Law During the COVID-19 Public Health Emergency

The Centers for Medicare and Medicaid Services (CMS) has issued blanket waivers of the Stark Law during the COVID-19 public health emergency…
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Ropes & Gray LLP | USA | 2 Apr 2020

COVID-19 Stark Law Waiver

On March 30—but retroactive to March 1—the Secretary of HHS issued a partial waiver of elements of the Stark Law. The waiver is subject…
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Holland & Hart LLP | USA | 1 Apr 2020

CMS Waives Stark Law Limits to Hospital-Physician Arrangements During COVID-19 Pandemic

On March 30, 2020, CMS opened the way for hospitals to provide additional compensation and/or support to referring physicians during the COVID-19…
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Holland & Hart LLP | USA | 31 Mar 2020

CMS Expands Blanket Waivers to Help Hospitals and Other Providers

On March 30, 2020, CMS issued numerous additional blanket waivers to give providers greater flexibility in responding to COVID-19. (See https://www…
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Bass Berry & Sims PLC | USA | 13 Feb 2020

Healthcare Fraud & Abuse Review

Ensuring compliance with the False Claims Act has never been more important for healthcare providers. Governmental personnel and policy changes along…
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