CMS and OIG recently proposed the most significant changes to the Stark Law rules, the Anti-Kickback Statute (AKS) safe harbors and the Beneficiary Inducements CMP regulations that the agencies have offered in recent years. The proposed rules address value-based arrangements, introduce major changes to other key Stark Law concepts and definitions, address the donation of cybersecurity technology and services, and create flexibility to provide patient incentives in value-based arrangements and with respect to telehealth. Click here to read King & Spalding’s Client Alert highlighting the key proposals.
We are hosting a two-part webinar series to discuss these proposals in greater detail, described below. We will cover the opportunities raised by these proposals, as well as how they may impact enterprise risk and future enforcement actions. Our goal is to stimulate thinking about the submission to CMS and OIG of comments on these proposed rules, which are due on December 31, 2019.
- In Part One, we will discuss proposed changes other than those relating to value-based arrangements and patient incentives. The topics will include the proposed changes to fundamental Stark Law concepts such as taking into account the volume or value of referrals or other business generated, fair market value, commercial reasonableness and the definition of indirect compensation arrangements. We also will address proposed changes to the writing requirements, proposed changes to several commonly used compensation exceptions and proposals related to cybersecurity technology and related services.
- In Part Two, we will discuss proposals related to value-based arrangements and patient incentives. This will include the newly proposed AKS safe harbors and Stark Law exception for value-based arrangements, modifications to existing AKS safe harbors and Stark Law exceptions to address value-based arrangements, newly proposed AKS safe harbors for patient incentives, revisions to the local transportation safe harbor and a proposed telehealth exception to the Beneficiary Inducements CMP.
Thursday, November 7, 2019
1:00 P.M. – 2:30 P.M. ET
Wednesday, November 20, 2019
1:00 P.M. – 2:30 P.M. ET
If you have questions concerning this roundtable webinar, email firstname.lastname@example.org.
King & Spalding is an accredited provider of CLE credit in California, Georgia, Illinois, New York and Texas. We can issue reciprocal credit for attorneys licensed in Connecticut, Florida, and New Jersey. We will apply for credit in Colorado, North Carolina and Virginia (subject to MCLE Board approval). For jurisdictions not listed, attendees are provided with a Universal Certificate of Attendance. New York licensed attorneys: Transitional/Appropriate for newly-admitted and experienced attorneys. Financial aid is available for qualifying lawyers. For CLE-related questions, please contact Gisel Arias, email@example.com. King & Spalding, 1180 Peachtree Street NE, Atlanta, GA 30309. CA Provider #10947.