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CMS Improves Stark Advisory Opinion Process


CMS Improves Stark Advisory Opinion Process | Baker Donelson

The update liberalizes and improves CMS's process for issuing advisory opinions on the application of the Physician Self-Referral (Stark) Law.

Advisory Opinions (AOs) - CMS

The purpose of the advisory opinion process is to provide a binding opinion concerning the application of section 1877 of the Act to specific ...

CMS Proposes Welcome Changes to Stark Law Advisory Opinion ...

In releasing the proposed rule, CMS explained that it intends to simplify the process for requesting advisory opinions and will provide the ...

CMS Proposes Changes to Stark Law Advisory Opinion Process

Moreover, in the proposed rule, CMS admits that the existing advisory opinion process has not been heavily utilized by stakeholders, with only ...

CMS Proposes Changes to its Stark Law Advisory Opinion Process

CMS may be anticipating that with increased charges and the collection of fees it may be able to allocate additional resources to increase the ...

Key Takeaways from CMS' New Proposed Rule on Stark Law ...

Although notable, it seems unlikely that these changes will significantly increase the use of the CMS advisory opinion process or, as the ...

CMS Proposes Liberalizing the Stark Advisory Opinion Process

CMS can only issue favorable advisory opinions for arrangements that do not violate the Stark law, because its advisory opinion authority is ...

Centers for Medicare and Medicaid Services Reforms Stark Advisory ...

... CMS received a number of comments about ways that the Stark advisory opinion process could be improved. In the preamble to its final rule, CMS explained ...

CMS Finalizes Changes to the Stark Advisory Opinion Regulations

Under the CMS advisory opinion process, the regulations for which are found at 42 C.F.R. §§ 411.370–389, parties can seek an advisory opinion ...

CMS Publishes Proposed Amendments to Stark Law Advisory ...

CMS is not proposing to expand the AO process to include hypothetical fact patterns or general questions of interpretation at this time but ...

Comments due to CMS by September 27 on proposed changes to ...

In August 2019, the Centers for Medicare & Medicaid Services released proposed changes to its Stark Law advisory opinion process. CMS intends for these ...

CMS Advisory Opinion Provides Flexibility Under Stark for Group ...

CMS Advisory Opinion Provides Flexibility Under Stark for Group Practice Structures Involving Wholly-Owned Physician Practice Subsidiaries ...

Advisory Opinions FAQs | Office of Inspector General - HHS.gov

... (CMS), which operates the Medicare and Medicaid programs. Information about the Stark advisory opinion process is available at 42 CFR §§ 411.370-.389. The Stark ...

Physician Self-Referral - CMS

In 1997, Congress added a provision permitting the Secretary to issue written advisory opinions concerning whether a referral relating to ...

CMS Opines That Stark Isn't That Stark – Advisory Opinion Guidance ...

A CMS advisory opinion [Advisory Opinion No. CMS-AO-2021-01] issued in June 2021 provides guidance that a parent-subsidiary medical practice ...

Physician Practice Acquisition Strategy: CMS Stark Advisory Opinion ...

CMS recently issued a Stark Advisory Opinion, which may offer additional flexibility for physician practices in growth mode. CMS-AO-2021-01 ...

Spotlight - CMS

On March 30, 2020, CMS issued blanket waivers of sanctions under the physician self-referral law for COVID-19 Purposes. These blanket waivers ...

Advisory Opinion FAQ - HHS.gov

However, no person or entity can rely on an advisory opinion issued to someone else. What law applies to the OIG advisory opinion process? Congress established ...

CMS Issues Proposed Rule on Stark Law Advisory Opinions

Broaden Scope of Advisory Opinions – Currently CMS accepts advisory opinion requests that involve arrangements that already exist and arrangements that a ...

Physician-Owned Hospitals - CMS

At this time, POHs should not submit a completed CMS-855POH (or a completed Attachment 1) for purposes of the physician self-referral law ...