CMS further crystalizes Stark liberalizations

On July 12, 2018, CMS included within the CY 2019 Physician Fee Schedule (the “Proposed Rule”) two revisions to Stark Law regulations aimed at further clarifying any actual or perceived differences between current regulations and the recently enacted Bipartisan Budget Act of 2018 (“2018 BBA”). As we previously reported, Section 50404 of the 2018 BBA codified certain Stark Law guidance promulgated through CMS rulemaking and commentary in 2015, as covered here. First, CMS has proposed a new special rule on compensation arrangements regarding the satisfaction of the writing requirement by a “collection of documents.” This new rule would codify existing policy that allows the writing requirement for excepted compensation arrangements to be satisfied by a “collection of documents,” including contemporaneous documents evidencing the course of conduct between the parties. While the “collection of documents” concept began as a…

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