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Health Care

CMS Issues Supplemental Guidance on Interim Final Rule on Vaccination for States Impacted by Recent Supreme Court Ruling

On January 14, 2022 the U.S. Centers for Medicare and Medicaid Services (“CMS”) issued supplemental guidance (the “Supplemental Guidance”) for implementation of its Interim Final Rule – Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff Vaccination (“CMS Rule”). 

Scope of Guidance

The…

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Had Enough Compliance Challenges? Don’t Forget About the Stark Law’s Group Practice Compensation Changes Effective January 1, 2022

Most health care providers face many compliance challenges in today’s regulatory climate with the promise of many more to come in the new year. This burden may be particularly acute for physician group practices who must change the methodology for pooling and distributing overall profits under an…

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Dollars to Donuts - Sunshine Audit Review

Although most physicians have heard about the Physician Payments Sunshine Act (the “Sunshine Act”) and have seen reports of the payments physicians have received from reporting drug and medical device companies, few physicians take the time to review or correct their own records. 

Many physicians…

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Is Your ASC Too Cheap?

The development and growth of ambulatory surgery centers (“ASCs”) has continued and even accelerated in recent years. Shifts in allowable cases from inpatient to outpatient, temporary closures of hospital outpatient departments because of COVID, and private equity funding have all bolstered this…

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