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Friday, January 15, 2021 On Nov. 20, 2020, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) and the Centers for Medicare and Medicaid Services (CMS) issued two final rules, which implement changes to the Anti-Kickback Statute (AKS) and Physician Self-Referral Law (Stark Law) regulations (respectively the OIG Final Rule and the CMS Final Rule, collectively the Final Rules). [1] This alert is a part of the Dinsmore Health Care practice group’s ongoing summary of the Final Rules. In an attempt to transform the health care system into “one that pays for value,” the Final Rules provide new exceptions and safe harbors for value-based arrangements. The Final Rules are intended to allow more flexibility and additional avenues for health care providers to structure value-based arrangements. Existing value-based arrangements that are already in compliance with a Stark exception or AKS safe harbor are not required to use one of the new exce

Ashley durnerCenters for medicareHuman servicesOffice of inspectorDepartment of healthDinsmore health careMedicaid servicesInspector generalAnti kickback statutePhysician self referral lawStark lawFinal rulesFull financialPhysician bears financialValue based arrangement satisfies specificHealth care