December 8, 2020

On November 20, 2020, the Centers for Medicare & Medicaid Services (CMS) and the Department of Health and Human Services (HHS) Office of Inspector General (OIG) finalized rules creating new exceptions to the Federal Physician Self-Referral or “Stark Law” and safe harbors under the Federal Anti-Kickback Statute (AKS). Building on our initial reactions to the historic changes to the Stark and Anti-Kickback rules, we have taken time to digest and provide a more comprehensive analysis of the implications of the new rules, particularly for the development of value-based care.

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