On July 2, 2007, the Centers for Medicare & Medicaid Services (CMS) released a number of proposed and potentially far-reaching changes to the Stark regulations as part of its annual physician fee schedule update. Foley Partner Charles B. Oppenheim and Associate Elizabeth O’Keeffe addressed proposed Stark revisions, including:
- Per click leases
- Percentage compensation
- In-office ancillary services
- Under arrangements
- Anti-markup
- Burden of proof
- Alternative criteria for satisfying exceptions
- Other proposed changes
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