November 18, 2019

HHS Issues Landmark Proposed Regulations for Stark, AKS and the Beneficiary Inducements Provision of the CMP Statute

By Reesa N. Benkoff, Esq. Benkoff Health Law, PLLC, Bloomfield Hills, MI and Donald H. Romano, Esq., Foley & Lardner, LLP, Washington, DC

On October 9, 2019, the Department of Health and Human Services (HHS) revealed its long-awaited proposals to update the Physician Self-Referral Law (Stark), the federal Anti-Kickback Statute (AKS), and the Beneficiary Inducements provision of  the Civil Money Penalty (CMP) Statute as part of its Regulatory Sprint to Coordinated Care.1 The proposed regulations promote and remove barriers to value-based arrangements and care coordination, in addition to easing compliance burdens associated with existing regulatory provisions.2 

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