General Surgery Coding Alert - 2020 Issue 11
Fraud & Abuse: Don’t Bank on the Stark Revamp Until 2021
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Article Overview
This article covers federal fraud and abuse policy developments related to the Stark Law and the Anti-Kickback Statute, including delayed final rule timing, temporary COVID-19 blanket waivers, and the anticipated transition away from pandemic-era flexibilities. It is relevant to providers, compliance teams, legal counsel, and revenue integrity staff who need to monitor CMS and OIG guidance and prepare for post-PHE operations. The discussion focuses on regulatory timelines, waiver updates, and the broader compliance implications of changes under review by CMS and the HHS Office of Inspector General.
Why This Topic Matters
Organizations may need to adjust financial relationships and compliance processes before temporary COVID-19 flexibilities end. Staying aware of the rulemaking timeline helps teams plan for operational changes and avoid fraud-and-abuse risk during the transition.
Article Sections
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Pocket This Stark Rundown and Timeline
Overview of the federal Stark Law rulemaking timeline and related agency activity. The section places the update in the context of CMS and OIG fraud-and-abuse policy developments.
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Plan Now for Post-COVID Compliance
Discussion of COVID-19-related waiver flexibilities and preparation for the period after the public health emergency ends. The section addresses general compliance planning considerations for providers and facilities.
What You Will Learn
- How recent federal announcements affect the timing of Stark Law and AKS policy updates
- What categories of temporary waiver guidance were issued during the COVID-19 public health emergency
- Why compliance planning matters as pandemic-era flexibilities wind down
- Which agencies are involved in fraud and abuse rulemaking and guidance updates
Who Should Read This
- Healthcare providers
- Compliance officers
- Health law attorneys
- Revenue cycle and reimbursement staff
- Practice managers
- Hospital administrators
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