Publications by Alyssa C. James

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Court Confirms Value in Obtaining Advisory Opinion from OIG

[04/28/25]

2025 Non-Monetary Compensation to Physicians (and Chance to Review 2024)

[12/31/24]

OIG Greenlights Specific Arrangement Involving Gift Cards Offered by Consulting Firm to Physician Practices in New Advisory Opinion

[04/04/24]

Non-Monetary Compensation to Physicians: New Limits for 2024 and Chance to Review 2023

[12/27/23]

OIG Signals Expansion to Its Exclusion Authorities

[08/09/23]

The End Is Near – Stark Law Blanket Waivers Set to Terminate May 11

[02/20/23]

2023 Non-Monetary Compensation to Physicians (and Chance to Review 2022)

[12/06/22]

OIG “Focused” on Eye Group’s Free or Reduced-Cost CME Program

[08/02/22]

CMS Proposes Revised Process for Group Practices Self-Disclosing Stark Law Violations

[06/29/22]

2022 Non-Monetary Compensation to Physicians (and Chance to Review 2021)

[12/09/21]

OIG Provides Favorable Opinion and Roadmap for ASC Joint Ventures

[07/29/21]

CMS Relaxes Exclusive-Use Leasing Requirements, With a Catch

[07/09/21]

Six-Month Recap: 2021 Brings Big Changes to Physician Compensation

[07/09/21]

Medical Groups Should Prepare Now: Changes to the Stark Law’s Group Practice Rules Are Coming

[04/30/21]

The Finish Line Is Here: New Stark and Anti-Kickback Regulations Take Effect Today

[01/19/21]

Defining Opportunity in the Sprint to Value: CMS and OIG Finalize Value-Based Definitions in Connection with New Stark Exceptions and Anti-Kickback Safe Harbors

[01/12/21]

Physician Arrangements Must “Pass Go” Under the Stark Law’s New Bright-Line Compensation Rules

[12/30/20]

CMS Provides Additional Expansion Opportunities for Certain Physician-Owned Hospitals

[12/22/20]

2021 Non-Monetary Compensation to Physicians (And Chance to Review 2020)

[12/21/20]

Sprinting Toward Value: OIG Overhauls Anti-Kickback Safe Harbors to Benefit Patients and Providers

[12/07/20]

The Sprint to Value: CMS Transforms the Stark Law

[12/04/20]

The Finish Line Is Here: CMS and OIG Finalize Transformative Stark and Anti-Kickback Regulations

[11/20/20]

Almost to the Finish Line: Proposed Stark and Anti-Kickback Rules Await Finalization

[08/20/20]

EKRA Enforcement Developments and Moving Forward

[05/18/20]

CMS Explains Stark Waivers – Consider Any Needed Action Now

[04/24/20]

CMS Issues New Blanket Stark Waivers for COVID-19 Purposes

[03/31/20]

The COVID-19 Effect on Physician/APP Arrangements and Compensation Plans

[03/24/20]

2020 Non-Monetary Compensation to Physicians (And Chance to Review 2019)

[12/23/19]

CMS Makes Value the Centerpiece of Proposed Stark Rules

[10/10/19]

Sprinting Toward Value: OIG Proposes Regulations Benefiting Patients and Providers

[10/09/19]

Stakeholders Asked and CMS Listened – Agency Proposes to Modify Stark Law Advisory Opinion Process

[08/13/19]

Need a Lyft to See Your Doctor? Arizona Medicaid Will Now Cover Ridesharing Service

[08/06/19]

Patient Transportation — How to Legally Get Patients in the Door

[03/27/19]

Digital Medicine: OIG Approves Arrangement to Provide Smartphones to Patients

[02/15/19]

Affordable Health Care: Patients’ Co-Pays Waived by Charitable Pediatric Clinic

[02/12/19]

Discount Disruption: PBM Rebate Protection May Be Removed, New Safe Harbors Combat Increasing Drug Costs

[02/01/19]

2019 Non-Monetary Compensation to Physicians (And Chance to Review 2018)

[12/19/18]

New All-Payor Kickback Statute Affects Arrangements Related to Clinical Laboratories, Recovery Homes and Clinical Treatment Facilities

[12/03/18]

OIG Requests Information from Stakeholders to Expand Anti-Kickback Statute and Civil Monetary Penalty Safe Harbors

[09/14/18]

Stark Regulations Proposed to Enhance Consistency and Flexibility

[07/20/18]

OIG Approves Arrangement to Provide Free DME Samples

[06/06/18]

CMS Issues Reminder for Change in Ownership Reporting

[01/30/18]

OIG Approves Gainsharing Arrangement for Surgical Procedures

[01/18/18]

2018 Non-Monetary Compensation to Physicians (And Chance to Review 2017)

[12/15/17]

Department of Justice Announces $42 Million Settlement for Alleged False Claims Act Violations

[08/08/17]

OIG Approves Waiver of Cost-Sharing Amounts for Financially Needy Beneficiaries Participating in Clinical Research Studies

[07/18/17]

Stark Law self-disclosure forms: A new hurdle in the provider landscape

Companion Legislation Repealing Moratorium on Physician-Owned Hospitals Introduced in Senate

[06/21/17]

CMS Seeks Comments on Role of Physician-Owned Hospitals

[04/27/17]

Stressful or Streamlined? CMS’s New SRDP Disclosure Form Presents New Challenges for Providers

[04/14/17]

Will Repeal and Replace Lift the Moratorium on Physician-Owned Hospitals?

[03/02/17]

OIG Scrutinizes Lab Relationships with Dialysis Facilities in Unfavorable Advisory Opinion

[12/20/16]

OIG Issues Sweeping Rulemaking Addressing Beneficiary Inducements

[12/08/16]

2017 Non-Monetary Compensation to Physicians (And Chance to Review 2016)

[11/30/16]

OIG Approves Collaboration to Subsidize Patient Transportation

[10/13/16]

OIG Approves Provision of Free Vaccine Management Systems in Favorable Advisory Opinion

[10/06/16]

CMS Bundled Payment Proposed Rule Details Changes to the Comprehensive Care for Joint Replacement Model

[08/09/16]

CMS Issues Notice of Proposed Rulemaking for New Bundled Payment Models

[08/09/16]

CMS Proposes Changes to Pain Management Assessments Under Value-Based Purchasing Program

[07/21/16]

Chapter 6: The Volume or Value Standard: Navigating the Stark Law's Prohibition on "Taking Into Account" Designated Health Service Referrals, THE BVR/AHLA GUIDE TO HEALTHCARE INDUSTRY FINANCE AND VALUATION (4th ed. 2016).

Health Care Fraud and Abuse Control Program Annual Report and Future Trends

[06/20/16]

Medical Equipment Company Agrees to Record-Setting Anti-Kickback Settlement

[03/08/16]

Failure to Be “Primarily Engaged” in Patient Care Puts Hospitals’ Medicare Provider Agreements at Risk

[03/02/16]

Physician-Owned Hospital Performance May Provide Support for Lifting Expansion Moratorium

[01/28/16]

2016 Non-Monetary Compensation to Physicians (And Chance to Review 2015)

[12/09/15]

OIG Approves Free Patient Transportation Service in Favorable Advisory Opinion

[11/04/15]

CMS Finalizes Proposed Rule Regarding Physician-Owned Hospital Advertising Requirements and Methodology Used to Calculate Physician Investment Levels

[11/03/15]

CMS Issues Final Regulations for Previously Proposed Modifications to Stark Law

[11/02/15]

Texas Hospitals Seek Declaratory Judgment Against HHS to Halt Physician-Owned Hospital Expansion

[10/30/15]

Study: Physician-Owned Hospitals Score Similarly on Patient Population, Costs and Quality Metrics

[09/21/15]

OIG Issues Report Addressing Ownership Overlap Between Physician-Owned Hospitals and Physician-Owned Distributors

[08/27/15]

Several Modifications Underway for Physician-Owned Hospitals

[07/13/15]

CMS Issues Sweeping Proposed Rule with Many Stark Law Modifications

[07/09/15]

Health Subcommittee Holds Hearing on Physician-Owned Hospital Expansion Moratorium

[05/22/15]

Congress Moves to Permanently Repeal Vexatious SGR – Bill Removes Barriers to Hospital-Physician “Gainsharing” Programs

[03/27/15]

CMS Rolls Out Voluntary Physician-Owned Hospital Self-Referral Disclosure Protocol

[03/05/15]

OIG Issues Favorable Opinion on Preventive Care Program Incentives

[02/25/15]

CMS Issues Advisory Opinion Analyzing Baseline Physician Ownership Percentages

[02/17/15]

CMS Delays Reporting Requirement for Physician-Owned Hospitals

[02/02/15]

2015 Non-Monetary Compensation to Physicians

[01/07/15]

CMS Issues Amended Final Rule Impacting Physician-Owned Hospital Expansion Requests

[11/11/14]

CMS Approves First Physician-Owned Hospital Expansion Request

[11/03/14]

OIG Offers Glimpse of New Hospital-Patient and Physician Arrangements

[10/20/14]

CMS Receives Comments to Proposed Rule Affecting Physician-Owned Hospital Expansion Exception

[10/08/14]

OIG Scrutinizes Specialty Pharmacy Arrangement in Unfavorable Advisory Opinion

[08/26/14]

CMS Issues Proposed Rule Affecting Physician-Owned Hospital Expansion Requests

[07/16/14]

OIG Terminates Previous Advisory Opinion Regarding Fee Structure of EHR Exchange

[06/05/14]

OIG Approves Senior Community Referral Arrangement

[03/06/14]

Urgent Reminder to Physician-Owned Hospitals: Action Required by March 1, 2014

[02/11/14]

Got Safe Harbor Comments?

[01/28/14]

Physician-Owned Hospitals: Addition of Unlicensed Observation Beds Does Not Increase the Hospital’s Number of Licensed Beds

[12/16/13]

OIG Disapproves of Part-Time Physician Arrangement Related to Hospital-Based Exclusive Contract

[12/03/13]

CMS Issues Advisory Opinions 2013-01 and 2013-02 Regarding Clinical Labs’ Provision of Devices to Physicians

[11/20/13]

CMS Issues Advisory Opinions 2013-01 and 2013-02 Regarding Clinical Labs’ Provision of Devices to Physicians

[11/11/13]

Gestational Surrogacy Agreements: Why Indiana Should Honor Them and What Physicians Should Know Until They Do, 10 Ind. Health L. Rev. 175, 2013.