Stacey Murphy (US)

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CMS Publishes Final Guidance for Hospital Co-location with Other Hospitals or Healthcare Facilities

By Stacey Murphy (US), Mark Faccenda (US), Thomas Dowdell (US) and Hayley White (US) on November 16, 2021 Posted in General, Regulatory

On November 12, 2021, the Centers for Medicare & Medicaid Services (“CMS”) issued its final guidance for hospitals to clarify how CMS and state agency surveyors will evaluate space-sharing or contracted staff and service arrangements with other hospitals or healthcare providers for compliance with the Medicare Conditions of Participation (“CoPs”). According to CMS, “[c]o-location occurs … Continue reading

US regulators to align key health care regulations with transformation to value-based care system; CMS and OIG propose major overhaul of Stark Law and AKS regulations

By Thomas Dowdell (US), Debbi Johnstone (US), Stacey Murphy (US) and Benjamin Wallfisch (US) on October 14, 2019 Posted in General, News from DC, Regulatory

On October 9, 2019, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued two sweeping proposals aimed at revising the Stark Law and Anti-Kickback Statute (AKS) regulations to adapt to and promote the US health care system’s transformation to value-based payment … Continue reading

CMS proposes Stark Law liberalizations

By Debbi Johnstone (US), Stacey Murphy (US) and Joseph Keillor (US) on July 13, 2015 Posted in Regulatory

On July 8, CMS proposed significant changes to the Stark Law via a far-reaching proposed rule and commentary that would—and in a few cases may already—eliminate numerous technical traps under the current regulatory scheme. From eliminating time limitations in connection with ‘holdovers’ of existing arrangements, to affording greater flexibility in signature timing, to clarifying that … Continue reading