Earlier this week, CMS, under its 1135 authority, published a number of blanket waivers of sanctions that otherwise apply to violations of the Stark physician self-referral law, if certain conditions are met. Yesterday, the OIG published a policy statement regarding enforcement of the anti-kickback statute for such arrangements described in the Stark blanket waivers. Although the OIG does not have waiver authority, the agency's statement is an
affirmative statement that the conduct described in the 1135 Stark blanket waivers issued by CMS will not be subject to OIG's administrative sanction. Attached is a link to the OIG policy statement.
https://oig.hhs.gov/coronavirus/OIG-Policy-Statement-4.3.20.pdf------------------------------
Thomas Greeson JD, FRBMA
Partner
Reed Smith LLP
Mc Lean VA
(703) 641-4242
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