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Phase I Final Stark Rule Issued

Client Alert | less than 1 min read | 01.31.01

On January 4, 2001, HCFA published the first phase of the long-awaited final rule implementing the federal Ethics in Patient Referrals Act (the "Stark Law") expansion to include ten designated health services. Click here for Crowell & Moring's analysis of the final regulation.

Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...