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CHA Comments on Proposed Changes to Stark Law

For CEOs, CFOs, chief legal counsel, government relations staff

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CHA has submitted its comment letter on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule to modernize regulations under the physician self-referral law – also known as the Stark Law. While CHA generally supports many of the provisions outlined in the proposed rule, additional changes are needed to advance the shared goals of care coordination and reduced administrative burden. 

In its letter, CHA outlines the unique challenges to Stark Law compliance and the greater impact of the law’s constraints faced by California hospitals because of certain state laws. CHA encourages CMS to consider important refinements to the rule to eliminate unintended obstacles that many providers, especially in California, will likely experience in attempting to satisfy the proposed value-based exceptions as currently drafted. CHA’s comments also detail changes and clarifications it proposes to reduce current Stark Law burdens.