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STARK II PHASE III: A Detailed Section-By-Section Analysis of the Long-Awaited “Final” Rule

Client Alert | 11 min read | 10.02.07

 The Crowell & Moring Health Care Group is pleased to provide our clients, colleagues, and friends with our legal analysis of the Stark II Phase III Regulations, recently published in the September 5, 2007 Federal Register. These new regulations present both welcome relief and unanticipated future challenges in the manner in which physician financial relationships with DHS entities are structured. Our goal in preparing this analysis was to create a thoughtful, practical, and "user-friendly" Stark Law resource that incorporates references to prior rulemaking as well as to the proposed 2008 Medicare Physician Fee Schedule Rule. We hope you'll agree that we have accomplished this goal. As always, please feel free to contact your regular Crowell & Moring attorney if you have any questions regarding the analysis, which can be accessed by clicking on the image or link below.




www.crowell.com/pdf/expertise/healthcare/StarkLaw_2007.pdf


Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....