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: https://www.federalregister.gov/articles/2015/07/15/2015-16875/medicare-program-revisions-to-payment-policies-under-the-physician-fee-schedule-and-other-revisions http://www.gpo.gov/fdsys/pkg/FR-2015-07-15/pdf/2015-16875.pdf Perhaps the most noteworthy of the lesser proposals were clarifications that: “hold over arrangements” are permitted to satisfy the … Continue Reading
