August 5, 2015 by Todd Christman
On July 15, 2015, the Centers for Medicare & Medicaid Services (CMS) published the Calendar Year 2016 Physician Fee Schedule Proposed Rule. The Proposed Rule includes several clarifications and proposed modifications to the Stark Law regulations, including the creation of two new exceptions. The Proposed Rule appears to reflect two key themes:
• CMS is seeking to ease the burden of certain Stark Law requirements, thereby reducing the need for providers to self-disclose certain “technical” violations of the Stark Law.
• CMS has proposed changes to the Stark Regulations and seeks comments regarding whether additional guidance and rule-making is needed to promote health reform initiatives, including alternate payment models and value-based purchasing.
Though the Proposed Rule will not be finalized until late fall 2015, there are several areas in which CMS clarified its position on existing regulations, and providers may rely on those clarifications as they review past and present conduct. Below are the top ten Stark Law takeaways from the Proposed Rule.
You can find the ten takeaways as well as the full text of the Proposed Rule at Drinker Biddle Health Care.
You can find the ten takeaways as well as the full text of the Proposed Rule at Drinker Biddle Health Care.
