Tag Archives: AKS

CMS and OIG Ring in the New Year with Final Rules on EHR Donations

By Elizabeth Trende on Posted in Department of Health and Human Services, Electronic Health Records, False Claims Act, Fraud and Abuse, Hospitals, Mergers and Acquisitions, Regulatory Compliance, Technology
On December 27, 2013, the Centers for Medicare and Medicaid Services (“CMS”) and the Office of Inspector General of the Department of Health and Human Services (“OIG”) published final rules (“Final Rules”) regarding the electronic health records (“EHR”) donations Stark Law Exception (42 C.F.R. 411.357(w)) and Anti-Kickback Statute Safe Harbor (“AKS Safe Harbor”) (42 C.F.R. … Continue Reading

Proposed ACO Waiver Regulations: Not Far Enough? An OIG Challenge During My Presentation at Friday's AHLA Medicare and Medicaid Institute

By Squire Patton Boggs on Posted in Accountable Care Organizations, Regulatory Compliance
Does anyone else feel that the proposed waiver regulations don’t go far enough? Do you think they allow providers to engage in flexible arrangements that deliver value to the government? The key is how the government has limited the waiver proposals mostly only to the shared savings distributions. That seems too narrow, although I think … Continue Reading
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