On December 2, 2020, the Centers for Medicare and Medicaid Services (CMS) issued a Final Rule that includes important changes to the federal physician self-referral law, commonly referred to as the “Stark Law.”  In general, the Stark Law prohibits a physician from making a referral for certain “designated health services” (DHS) to an entity with which the physician (or an immediate family member) has a financial arrangement, unless an exception applies.  Concurrently with the Stark Law changes, the Office of Inspector General also issued new rules under the Federal Anti-kickback Statute, which will be addressed in separate client alerts.
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