Kelsey Leingang Kelsey Leingang

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Kelsey J. Leingang provides transactional and regulatory counseling to health care organizations, including hospitals, health systems, physician groups and other health industry providers. Read Kelsey J. Leingang's full bio.

CMS Seeks Comments on Stark Law Reforms Needed to Reduce Obstacles to Innovation


By , , , , , and on Jul 3, 2018
Posted In Stark

On June 25, 2018, the Centers for Medicare and Medicaid Services (CMS) published a request for information, seeking input from the public on how to address any undue regulatory impact and burden of the physician self-referral law (Stark Law) on value-based and other coordinated care arrangements designed to improve quality and lower cost. While the...

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‘Tis the Season for Giving: OIG Updates Policy on Gifts of Nominal Value to Medicare and Medicaid Beneficiaries


By , , and on Dec 12, 2016
Posted In Anti-Kickback Statute / Stark Law

On December 7, 2016, the Office of the Inspector General (OIG) of the US Department of Health and Human Services (HHS) issued a policy statement increasing its thresholds for gifts that are considered “nominal” for purposes of the patient inducement provisions of the civil monetary penalties law (section 1128A(a)(5) of the Social Security Act) (CMP...

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