Tagged: Advisory Opinion

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CMS Advisory Opinion Approves Parent and Wholly-Owned Subsidiary Qualifying as “Single Legal Entity” under the Stark “Group Practice” Definition

The Centers for Medicare & Medicaid Services (“CMS”) released Advisory Opinion No. CMS-AO-2021-01 in June 2021, which gave the requestor the green light to provide designated health services (“DHS”) through wholly-owned subsidiaries while the parent and subsidiaries could qualify as a “single legal entity” under the “group practice” definition of the federal physician self-referral law...

OIG Guidance

OIG Advisory Opinion No. 21-02 Provides Helpful Insights into Risk Mitigation Factors Regarding Health System-, Physician-, and Management Company-Owned Ambulatory Surgery Centers

On April 26, 2021, the Department of Health and Human Services Office of Inspector General (“OIG”) issued favorable Advisory Opinion No. 21-02 regarding a proposed investment in an ambulatory surgery center (“ASC”) by a health system, orthopedic surgeon and neurosurgeon employees of the health system, and a management company. This latest Advisory Opinion is notable...

General / Healthcare Fraud and Abuse / Medicare / Medicaid / Regulatory Sprint

CMS Finalizes Changes to the Stark Advisory Opinion Regulations; 2020 DHS Code List and CPI-U Updates

In the calendar year 2020 Medicare physician fee schedule final rule (“PFS”), which was published in the Federal Register on November 15, 2019 (available here), CMS finalized changes to the advisory opinion process under the federal physician self-referral law (“Stark Law” or “Stark”).  CMS also published its annual update to CPT/HCPCS codes used to identify...

Data Privacy and Security / General / Healthcare Fraud and Abuse / Medicare / Medicaid / OIG Guidance

A Massive Number of New Health Law Regulatory Proposals as Part of the “Regulatory Sprint to Coordinated Care”: Proposed Changes to the Stark Law, Anti-Kickback Statute, Beneficiary Inducement CMP, Privacy Laws Governing Substance Use Disorder Records, and the Stark Law Advisory Opinion Process

Today, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services (HHS) Office of Inspector General (OIG) each released their long-anticipated proposed rules to revise the federal self-referral law (or “Stark Law”) regulations, the safe harbors under the federal anti-kickback statute (AKS), and the civil monetary penalty law (CMP)...

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avatar for Alissa SmithAlissa Smith

Alissa represents health systems, hospitals, pharmacies, long-term care providers, home he...

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Andrew's experience spans a wide range of industries, and has particular depth in...

avatar for Rebecca BrommelRebecca Brommel

Becki assists clients in the areas of litigation and administrative law wit...

avatar for Katie CownieKatie Cownie

Katie has worked on business and corporate issues for more than 20 years. Many of...

avatar for Lillie CoxLillie Cox

Lillie assists a wide array of healthcare industry clients with corporate transact...

avatar for Ross C. D'EmanueleRoss C. D'Emanuele

Ross works in the health care provider, payor, and drug and medical device segment...

avatar for Nathan EbnetNathan Ebnet

Nate represents clients in all stages of complex civil disputes, from pre-...

avatar for Elise FesterElise Fester

Elise counsels a wide variety of clients in the Health Care industry on regulatory...

avatar for Adam FreedAdam Freed

Adam provides strategic advice to health care providers through all stage...

avatar for Randall HansonRandall Hanson

Randall is an associate in Dorsey’s health transactions and regulations practice group.

avatar for Alan IversonAlan Iverson

Alan is a litigator in Dorsey’s trial group with a focus on clients in...

avatar for Michael JenkinsMichael Jenkins

Mike serves clients in highly regulated industries, including health care and gam...

avatar for Jamie McCartyJamie McCarty

Jamie counsels clients in the healthcare industry in connection with complex busi...

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Neal regularly advises clients regarding compliance with laws specific to the he...

avatar for Mara SandersMara Sanders

Mara regularly advises clients on matters of state and federal regulatory complia...

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Vanessa's practice focuses on litigation in the healthcare industry, including gen...

avatar for Claire H. ToppClaire H. Topp

Claire works in three diverse sectors – health care, tax exempt organizations,...

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