Day Pitney LLP is a full-service law firm with more than 300 attorneys in Boston, Connecticut, Florida, New Jersey, New York and Washington, DC. The firm offers clients strong corporate and litigation practices, with experience on behalf of large national and international corporations as well as emerging and middle-market companies. With one of the largest individual clients practices on the East Coast, the firm also has extensive experience assisting individuals and their families, fiduciaries and tax-exempt entities plan for the future.
In November 2011, the Centers for Medicare & Medicaid Services (CMS), along with the HHS Office of Inspector General, published an interim final rule regarding waivers from certain healthcare-related fraud laws for certain financial arrangements involving accountable care organizations (ACOs) under the Medicare Shared Savings Program (MSSP).
United StatesFood, Drugs, Healthcare, Life Sciences
In November 2011, the Centers for Medicare & Medicaid
Services (CMS), along with the HHS Office of Inspector General,
published an interim final rule regarding waivers from certain
healthcare-related fraud laws for certain financial
arrangements involving accountable care organizations (ACOs) under
the Medicare Shared Savings Program (MSSP). CMS issued a
continuation notice in the fall of 2014, but that continuation is
set to expire November 2, 2015.
On September 9, the White House Office of Management and Budget
announced that it is reviewing a final rule from CMS (CMS-1439-F; RIN 0938-AR30)
that establishes waivers of the application of the Physician
Self-Referral (Stark) Law, the federal Anti-Kickback Statute, and
certain civil monetary penalties (CMP) law provisions for specified
financial arrangements involving ACOs under the MSSP.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.