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Valuing Electronic Health Record System (“EHR”) Donation Arrangements

November 29, 2016 HealthCare Appraisers

On October 10, 2006, the Centers for Medicare and Medicaid Services (CMS) implemented exceptions to the Stark and Anti-Kickback rules which preclude EHR donations under the Medicare Modernization Act of 2003. These exceptions allow health entities to subsidize or donate EHRs to independent practices without violating the federal Anti-Kickback [...]

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Valuing Payments Under the “Refill Exception”

May 21, 2015 HealthCare Appraisers

HIPAA’s Privacy Rule (the “Privacy Rule”), among other rights, gives individuals important controls over whether, and how their protected health information (“PHI”) is used and disclosed for marketing purposes.  Generally, “marketing” is communication made to an individual about a product or service that encourages the individual to purchase or [...]

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