On June 20, 2018, CMS released a Request for Information (RFI) Regarding the Physician Self-Referral Law. The “Stark Law” is intended to disconnect a physician’s health care decision making from his or her financial interests in other providers or suppliers. CMS is aware of the burdensome effect Stark Law regulations can have on parties wishing to participate in integrated delivery models, alternative payment models (APMs), and arrangements that incentivize improved outcomes or lower costs. CMS seeks information on (1) the structure of arrangements between parties that participate in APMs or other novel financial arrangements, (2) specific revisions, additions, or exceptions to the Stark Law regulations needed for such arrangements, and (3) standard terminology related to APMs and Stark Law. AAHKS will prepare a response which is due to CMS by August 17, 2018. Read the RFI here.

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