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2019 Stark Law Proposed Rule

Publications - Client Alert | October 25, 2019


The Centers for Medicare and Medicaid Services published the Medicare Program; Modernizing and Clarifying the Physician Self-Referral Regulations Proposed Rule on October 17, 2019. 

This Proposed Rule provides significant clarifying guidance on the interpretation of existing Stark Law regulatory exceptions, proposes a number of new exceptions and proposes revisions to certain Stark Law exceptions.  If finalized, this Proposed Rule will have sweeping application to the analysis of financial arrangements between physicians and entities that furnish designated health services. 

Kutak Rock's Healthcare Practice Group has prepared a Client Alert that summarizes the Proposed Rule.  This Client Alert focuses primarily on the proposals in the Stark Law Proposed Rule; however, we note that the Office for Inspector General contemporaneously published an Anti-Kickback Statute and Civil Monetary Penalties Proposed Rule also proposes significant revisions to the regulatory text.

Client Alert: 2019 Stark Law Proposed Rule