Statute
Stark Law
366 published works
The FCA Insider
CMS Revises Protocol Form to Ease Disclosures of Missed In-Office Imaging Notices
By Timothy Fry, Amber McGraw Walsh, Kristen H. Chang, Gretchen Heinze Townshend, Varsha Gadani, Erica Jewell, Andrew Konia
The Centers for Medicare & Medicaid Services (CMS) recently posted revised forms for its voluntary self-referral disclosure protocol (SRDP), the process Medicare providers and suppliers use to self-disclose and resolve…
P.I.S.S.D.
Understanding Healthcare Compliance: What Providers Need to Know
By Bob Kraft
Healthcare compliance sits at the heart of every well-run medical practice or healthcare organization. Regulations shift, legal standards evolve, and governing bodies are paying closer attention than ever before. Falling…
Thompson Coburn LLP
Stark Self-Disclosure Protocol Changes: What Providers Need to Know Before November 1, 2026
The Centers for Medicare & Medicaid Services (“CMS”) recently updated its Voluntary Self-Referral Disclosure Protocol (“SRDP”), which allows health care providers and suppliers to voluntarily disclose actual or potential violations…
Agricultural Law & Rural Practice | Solo Small Firm & General Practice Section
OIG Clarifies That Stark Law Compliance and Fair Market Value Alone Do Not Resolve Anti-Kickback Statute Risk
By Hall Render
In revisions released earlier this year to its General Questions Regarding Certain Fraud and Abuse Authorities, the Office of Inspector General (“OIG”) emphasized that compliance with the physician self-referral law…
Criminal Jurisdiction
FEDERAL HEALTHCARE FRAUD
By Rebeca.pirela@alphacomarketing.com
Federal healthcare fraud is the intentional deception or misrepresentation to secure an unauthorized benefit or payment from any healthcare program. 18 U.S.C. § 24(b) defines a healthcare program as “any…
Health Law Rx
AI-Assisted Data Mining and the False Claims Act: Is a Data Anomaly Really a False Claim?
By Noam Fischman, Ameer Al-Khudari
Data miner whistleblowers, increasingly armed with artificial intelligence (AI) tools, are already reshaping how False Claims Act (FCA) theories are built, generated, and litigated. The Department of Justice's (DOJ) April…
Inside the False Claims Act
Smoke is Not Fire: Fourth Circuit Rejects Stark and AKS Theories Built on Ordinary Business Practices and Conclusory Allegations
It is not every day that an 83-page qui tam complaint alleging Stark Law and Anti-Kickback Statute (AKS) violations is dismissed at the pleading stage, particularly when filed by experienced…
The FCA Insider
HHS Inspector General Reminder: Kickback Liability Turns on Intent, Not Market Value or Stark Law Compliance
By Timothy Fry, Kristen H. Chang
The U.S. Department of Health and Human Services Office of Inspector General (OIG) updated its FAQs on Fraud and Abuse Authorities to add a new answer on fair market value…
Health Law Rx
Fair Warning: HHS OIG’s New FAQs Caution that Fair Market Value and Stark-Compliant Arrangements Can Nonetheless Violate the Federal Anti-Kickback Statute
By John Hood
Fair market value arrangements and those that satisfy an exception to the physician self-referral law (Stark Law) can nonetheless violate the federal Anti-Kickback Statute (AKS). That is the message of…
Health Law Diagnosis
OIG Reiterates a Core Message: Stark Compliance and Fair Market Value Alone Do Not Shield Against Anti-Kickback Statute Risk
On April 23, 2026, the HHS Office of Inspector General (OIG) quietly—but pointedly—added two new FAQs to its “General Questions Regarding Certain Fraud and Abuse Authorities.” Although the principles articulated…