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Client Alert

 

Legal Alert!
Far Reaching Stark Changes on the Horizon!?!

On July 2, 2007, the Centers for Medicare and Medicaid Services ("CMS") issued "Proposed Revisions to Payment Policies Under the Physician Fee Schedule and Other Part B Payment Policies for CY 2008" (the "Proposed Revisions").  While these proposed revisions are not the awaited Stark III regulations, and do not promulgate any final regulations, they are nevertheless noteworthy in that they contain extensive discussions by CMS of its concerns and thinking about a number of important subjects.  Even if only some of CMS's proposed revisions to the regulations were adopted, many presently common practices would be prohibited or restricted.  Moreover, CMS is seeking comments and guidance on ways to further limit what it perceives to be abusive under the existing already restrictive Stark provisions.

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