In July 2015, CMS released proposals to provide several new Stark Law exceptions and to clarify issues regarding existing exceptions.  The full text of these proposal and CMS comments and explanations is available at:

Perhaps the most noteworthy of the lesser proposals were clarifications that:

  • “hold over arrangements” are permitted to satisfy the appropriate exception indefinitely as long as the agreement was in place for the term of at least a year and otherwise complied with the exception requirements and
  • a proposal to modify the current regulations to allow parties 90 days to obtain required signatures, regardless of whether the failure to obtain the signature in the first place was inadvertent.