AACU News & Notes

AACU Comments on CMS Proposed Rule to Modernize Stark Law

posted: January 2, 2020

AACU submitted a formal comment letter to the Centers for Medicare and Medicaid Services (CMS) on December 31 in response to the agency's proposed rule that would create permanent exceptions to the physician self-referral rules ("Stark law") for value-based arrangements and enact a series of other patient-centered payer reforms.

The letter generally applauded CMS for modernizing the statute, enacted in 1989, that governs Medicare patient referrals and integrated care. In particular, AACU expressed support for 1) the creation of new value-based exceptions under Stark in order to foster greater cooperation between physicians, 2) greater clarification and improved definitions of compensation regulations, 3) simplification of documentation requirements, and 4) the distinction between substantive and technical violations of the law.

The letter concludes:

"In general, we believe these reforms will support urologists' ability to deliver high-quality care to their patients. We encourage CMS to finalize the proposed updates as quickly as possible in order to reduce regulatory burden, simplify and streamline compliance obligations, and facilitate the transition to innovative, value-based care models."

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