Health Panel Comment Letter – Anti-Kickback Statute – December 2019

The Panel is pleased to provide comment on the proposed rule Revisions to Safe Harbors Under the Anti-Kickback Statute, and Civil Monetary Penalty Rules Regarding Beneficiary Inducements. The Panel is encouraged by OIG’s recognition that there are certain circumstances that warranttreating rural providers differently than those in urban geographies. The Panel offers comments ontwo specific …

Health Panel Comment Letter – Stark Law – December 2019

The Panel is pleased to provide comments on the proposed rule Modernizing and Clarifying the Physician Self-Referral Regulations.The Panel is encouraged by CMS’s recognition throughout the proposed rule of the unique ruralhealth care environment. The Panel agrees that circumstances exist in which it is appropriate to treatrural providers differently than other kinds of providers. View …