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At the request of certain members of Congress, the Federal Trade Commission (FTC) has extended the enforcement date of the Red Flags Rule to June 1, 2010. Originally intended to be enforced on November 1, 2008, the FTC has delayed the enforcement date a number of times to ensure that those affected entities have adequate […]

On September 22, 2009, the U.S. Senate’s Chairman’s Mark released a draft legislation regarding the future of healthcare in the United States. Some notable points include: – Limiting physician referrals only to permit hospitals that meet certain exemption requirements, which would be more stringent than the current Medicare requirements; – Establishing a process to update […]

The current legislative initiatives to restrict (or eliminate) the In-Office Ancillary Services Exception (the “IOASE”) under Stark is, by no means, a new phenomenon. Rather, over the years, CMS has received a substantial number of comments from interested groups whose economic interests are adversely affected by the IOASE. In fact, the amendments to the Anti-Markup […]

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