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Transitioning Physicians to Value-Based Payment in A Regulatory Minefield: Will a New Interagency Task Force Lead the Way?

January 25, 2018 Andrea Ferrari, JD, MPH

Published: 01/25/2018 | Author: Andrea M. Ferrari, JD, MPH 

Since at least 2015, the Centers for Medicare and Medicaid Services (CMS), which is the Federal agency responsible for enforcing the Federal Physician Self-Referral Law (commonly known as the “Stark Law”), has acknowledged incongruity between the existing Federal law and regulations [...]

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Allegations of Improper and Excessive Physician Compensation

October 19, 2016 HealthCare Appraisers

Three times during September 2015, the Department of Justice (the “DOJ”) issued its now-familiar press release to announce a high-dollar-value settlement agreement to resolve allegations relating to improper and excessive compensation in hospital-physician arrangements.  All three settlements were the result of qui tam lawsuits and were among the [...]

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Newly Released OIG Fraud Alert Reiterates Physician Compensation Risks

June 19, 2015 HealthCare Appraisers

In June 2015, the Office of Inspector General (“OIG”) released a Fraud Alert to give notice to physicians that they may be subject to civil, criminal or administrative sanctions if they enter into medical directorship or other compensation arrangements that do not reflect “fair market value for bona fide services [the] physicians actually [...]

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