In late October 2020, the Departments of Health and Human Services (“HHS”), Labor (“DOL”), and Treasury (“DOT”) jointly released final regulations requiring group health plans and insurers to make available healthcare pricing to participants, beneficiaries, and the public. The regulations were issued in an effort to improve price transparency, give […]
Health Law Alert
New Stark & Anti-Kickback Rules: Changes to the Big 3 Under Stark — Fair Market Value, Commercial Reasonableness, and Tie to Referrals
On December 2, 2020, CMS finally issued the much anticipated additions and modifications to the Stark law and the federal Anti-Kickback Statute (AKS). The changes came over one year following the publication of proposed rules and, with a few exceptions, are effective as of January 19, 2021. This is one […]
The Wait is Over: The Stark Law and Anti-Kickback Statute Rules are Finalized
The much anticipated regulatory updates to the Physician Self-Referral Law (or “Stark”) and the Anti-Kickback Statute were published in the Federal Register on Tuesday, December 2, 2020. These final rules come about 14 months after the U.S. Department of Health and Human Services (“HHS”) and its sub-agencies proposed sweeping updates […]
OIG Special Fraud Alert Targets Speaker Programs and Fees Paid by Pharmaceutical and Medical Device Companies
The Office of Inspector General, U.S. Department of Health and Human Services (“OIG”) issued its first Special Fraud Alert since 2014, on November 16, 2020. Recognizing that the COVID-19 pandemic has caused cancellation of speaker programing on products sold by pharmaceutical and medical device companies (“vendor companies”), OIG questions the […]
New Nebraska Public Meetings Limited Waiver
On December 1, 2020, Nebraska Governor Pete Ricketts signed Executive Order No. 20-36 waiving certain requirements of the Nebraska Open Meetings Act for all “meetings” held by specified “public bodies” defined in the Open Meetings Act. The waiver would apply for the months of December 2020 and January 2021. The […]

