CMS recently released final rules for the Electronic Health Records Incentive Program (“Meaningful Use”). The final rules include modifications for program years 2015 through 2017 and also include the Stage 3 objectives and measures for eligible hospitals (“EHs”), critical access hospitals (“CAHs”) and eligible professionals (“EPs”). CMS’ goal is to […]
Publications
Recent Settlements Serve as a “Stark” Reminder – Pay Extra Attention to Physician Compensation Arrangements
This summer has seen heightened activity in the prosecution and ultimate settlement of False Claims Act cases brought by qui tam relators alleging violations of the Stark law and Federal Anti-Kickback Statute due to inappropriate compensation arrangements between physicians and hospitals. The amounts for which these cases ultimately settled should […]
Executing Successful Joint Ventures (Part 2): Frequently Asked Questions
How do you structure your cross-border joint venture? Although a flexible approach is needed when structuring a joint venture in order to properly negotiate and accommodate the diverse interests of the parties, there are certain required key conceptual elements of all joint ventures. The rights and obligations of the parties […]
Top Ten Business Succession Planning Mistakes
As business owners approach retirement age, many begin to focus on the next phase of their business – one that does not involve them. This article describes some of the major planning gaps common to business owner’s succession plans. 1. No business succession plan. Most business owners are experts in […]
Relief from SEC Broker-Dealer Registration for Private Company M&A Brokers
Among professionals engaged in mergers and acquisitions, there has been a long-standing concern that advisors participating in M&A transactions and receiving transaction-based compensation fall within the definition of “broker” under Section 3(a)(4) of the Securities Exchange Act of 1934 (Exchange Act), where the transaction takes the form of the sale […]