Practice Management

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  • 1.  OIG policy statement on AKS enforcement during COVID-19 crisis

    Posted 04-04-2020 10:49
    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

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    Thomas Greeson JD, FRBMA
    Partner
    Reed Smith LLP
    Mc Lean VA
    (703) 641-4242
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  • 2.  RE: OIG policy statement on AKS enforcement during COVID-19 crisis

    Posted 04-06-2020 07:27
    Gloves off to kick backs





  • 3.  RE: OIG policy statement on AKS enforcement during COVID-19 crisis

    Posted 04-06-2020 07:53

    Fortunately, that is not the case. Their non-enforcement announcement is aligned with the arrangements outlined the the blanket waivers to Stark sanctions described by CMS last week as a result of the COVID-19 crisis. 


    Thomas W Greeson
    Reed Smith LLP
    (703) 517-0495
    tgreeson@reedsmith.com