OIG’s Update to the Provider Self-Disclosure Protocol Offers Expanded Detail...
The updated Provider Self- Disclosure Protocol (SDP) issued April 17, 2013 by the OIG expanded and updated the original SDP issued on October 30, 1998 and the OIG's Open Letters to health care...
View ArticleNew MSA Status For Nebraska Counties May Impact Stark Physician Relationships
The U.S. Office of Management and Budget recently announced new Metropolitan Statistical Areas ("MSAs") based upon 2010 census data. In that announcement, a new MSA was created that includes Grand...
View ArticleAddressing Stark Liability: New FAQs Provide Additional Food for Thought
The Centers for Medicare and Medicaid Services ("CMS") recently released eight frequently asked questions concerning the Self-Referral Disclosure Protocol ("SRDP"). The SRDP is a product of the Patient...
View ArticleStark and FCA Damages Mount for Tuomey Healthcare System, Inc.
A second jury verdict in the whistleblower case filed under the False Claims Act eight years ago against Tuomey, the Sumter, S.C.-based health system, led to a federal district court order on September...
View ArticleSunset of the Stark and Anti-Kickback EHR Donation Exceptions
In 2006, CMS and the OIG promulgated a Stark exception and an Anti-Kickback safe harbor to encourage the development and adoption of interoperable electronic health record systems in communities. The...
View ArticleUpdate: EHR Donation Sunset Extended
At long last, the Office of Management and Budget (OMB) approved final rules extending the sunset on the Stark exception and an Anti-Kickback safe harbor. As addressed previously in this Health Law...
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