Proposed Changes to Stark, Anti-Kickback Statute and Civil Monetary Penalties Law

This month, CMS and the OIG issued their much anticipated proposed revisions to the federal Ethics in Patient Referrals Act (“Stark”), Anti-Kickback Statute and Civil Monetary Penalties Law. The changes are primarily intended to facilitate value-based purchasing arrangements, but also affect other key terms. Kim Stanger will be discussing the proposed rules in a free webinar on Friday, November 22, 2019, at 12:00 p.m. Mountain Time, including:

  • New definition of “fair market value” and “commercially reasonable”
  • Clarification concerning when compensation takes into account the volume or value of referrals
  • Modification to rules which allow an entity to condition compensation on referrals
  • New or significantly revised safe harbors for:
    • remuneration to physicians of less than $3500 per year
    • value-based purchasing arrangements
    • cybersecurity support
    • remuneration unrelated to the provision of DHS
    • provision of telehealth services to ESRD patients


Agenda: FRIDAY, NOVEMBER 22, 2019
12:00 - 1:00 PM MST


Speaker: Kim Stanger

Location: Webinar Only

Questions? Please contact Laura Squyres.

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