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As you know, we have been parsing through the HHSrules that finalize important changes to the Anti-Kickback Statute (AKS) and Physician Self-Referral Law (Stark Law) regulations. To recap, our team provided an overview of these historic changes before diving into new rules regarding beneficiary inducement and value-based arrangements. We’ve also provided two comparison charts – one on the AKS and the Beneficiary Inducements CMP and another on the Stark Law – that offer an easy-to-read comparison between the current, proposed, and final regulations.
Today, we are taking a look at changes to existing AKS safe harbors and Stark Law exceptions, and, an extra add-on: a new Stark Exception for Limited Remuneration to a Physician. Note that we plan to cover changes to the safe harbor and exception for donations of electronic health records items and services in a separate post, along with the new safe harbor and exception for donations of cybersecurity technology.