There has been much discussion and controversy over the new CMS position on billing for split/shared services in facility settings.
As originally proposed, and starting in January 2022, if the service was shared among providers (such as physicians and physician assistants), the provider who performed the substantive portion of the visit would be the provider…
There is almost universal agreement regarding predictions for 2022 federal enforcement in the following areas:
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Under the Federal Ethics in Patient Referrals Act (more commonly known as “Stark”), if a physician[1] has a financial relationship with an entity, the physician may not refer patients to the entity for medical services payable by Medicare unless the financial relationship complies with the Stark safe harbors. Thus, entities that lease or sublease…
