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Articles by Christopher Janney
CMS Finalizes Changes to Stark Law Regulations: Indirect Compensation Arrangement and Unit-Based Compensation Further Defined | JD Supra
In a December 2, 2020 rulemaking (2020 Final Rule), the Centers for Medicare & Medicaid Services (CMS) finalized a set of sweeping and significant revisions to the regulations implementing the federal physician self-referral statute (Stark Law).
CMS proposes further changes to Stark Law regulations: ICA definition and unit-based compensation could be drastically affected | JD Supra
In a December 2, 2020 rulemaking (2020 Final Rule), the Centers for Medicare & Medicaid Services (CMS) finalized the most sweeping and significant revisions in over a decade to the regulations implementing the federal physician self-referral statute (Stark Law). The bulk of the new regulations took effect earlier this year on January 19, 2021. CMS is now proposing an additional set of modifications to the Stark Law regulations (Proposed Rule).
CMS proposes further changes to Stark Law regulations: ICA definition and unit-based compensation affected | JD Supra
In a December 2, 2020 rulemaking (2020 Final Rule), the Centers for Medicare & Medicaid Services (CMS) finalized the most sweeping and significant revisions in over a decade to the regulations implementing the federal physician self-referral statute (Stark Law). The bulk of the new regulations took effect earlier this year on January 19, 2021. CMS is now proposing an additional set of modifications to the Stark Law regulations (Proposed Rule).
HHS-OIG issues new special fraud alert on speaker programs | JD Supra
On November 16, 2020, the U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG) published a new Special Fraud Alert on speaker programs sponsored by pharmaceutical and medical device companies. This marks the first Special Fraud Alert issued by the agency in over six years.
CMS proposed rules would extend certain telehealth flexibilities and expansions beyond the COVID-19 public health emergency | JD Supra
CY 2021 Medicare Physician Fee Schedule Proposed Rule On August 3, 2020, the Centers for Medicare and Medicaid Services (CMS) published the Calendar Year (CY) 2021 Medicare Physician Fee Schedule Proposed Rule (PFS Proposed Rule).
Seventh Circuit Decision May Portend Broader Definition of “Referral” Under Anti-Kickback Statute | JD Supra
On April 29, 2020, the U.S. Court of Appeals for the Seventh Circuit issued an opinion in Stop Illinois Health Care Fraud, LLC v. Sayeed reaffirming the court’s broad interpretation of the term “referral” under the federal health care program anti-kickback statute (Anti-Kickback Statute or AKS) as encompassing more than the explicit sending or directing of a patient to a provider.
HHS-OIG Issues Proposed CMP Rule | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CMS Issues "Explanatory Guidance" for Stark Law Blanket Waivers | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
ONC releases final rule to advance interoperability and enhance ease of access to, and use and exchange of, electronic health information | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CMS issues guidance on obligations and flexibility under Medicare Advantage and Part D programs arising from COVID-19 pandemic | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
In Wake of Coronavirus, Congress eases restrictions on Medicare telehealth coverage | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CMS proposes penalties for MSP reporting violations | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
HHS issues proposed Stark and AKS rules aimed at removing roadblocks to value-based care | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Recently passed drug misclassification legislation could impact 340B program stakeholders | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Trump administration FY 2020 budget request includes proposed changes to 340B | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
340B stakeholders await release of International Pricing Index Model proposed rule | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
New California drug pricing initiative could significantly impact 340B providers | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Update on HRSA’s forthcoming 340B ceiling price database | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
New 340B ceiling price and manufacturer CMP rule finally in effect: Implications for providers | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Federal Court concludes HHS exceeded authority with Medicare Part B payment cuts for 340B drugs, but holds off on specifying remedy | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
CODAawards - Design + Art Awards - 2018 Winners - CODAworx
“This is an excellent example of integrated design and collaboration. The entire space is a part of the experience and work. It could also be used for temporary events, creating a purposeful series of kaleidoscopic design.”
Hospital system pays $84.5 million to settle AKS and Stark Law violations | JD Supra
JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations. This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services").
Can value-based programs work with Stark Law limitations? - CMS requests industry input on potential modifications to the physician self-referral law | JD Supra
JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations. This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services").
Spring 2018 Art and Culture Festivals in Phoenix, Tempe, and Mesa
Spring is right around the corner. To help you plan out your days accordingly, we've compiled a list of spring festivals everyone can enjoy. If you're looking to indulge in art, culture, film, or just looking for a good time, we've got you covered. Get ready to watch thousands of lanterns light up the night sky. Besides the spectacular view, you can enjoy live music, food, stage performances, face painting, and s'mores.
CMS moves forward with controversial reductions in Medicare reimbursement for 340B drugs
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CMS Publishes RADV Medical Reviewer Guidance
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HHS-OIG blesses product replacement program
The federal health care program anti-kickback statute, 42 U.S.C. § 1320a-7b(b) (AKS), in addition to prohibiting payments for patient referrals, prohibits one party (such as a manufacturer) from providing anything of value to another party (such as a hospital) if the "remuneration" is intended to "induce" the recipient to "order" or "purchase" an item or service that is reimbursable by Medicare, Medicaid or certain other federal programs.
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