The Center for Medicare and Medicaid Services (“CMS”), on July 2nd, published their thoughts relating to the impending Stark III Rules. In addition to certain specific proposed rules, CMS solicited comments on several areas of concern. These proposed Stark III Rules tend to tighten up restrictions rather than add additional opportunities. While many of the proposed changes make sense given ongoing potentially abusive activities, the changes will not be viewed as physician-friendly. Nine of the key concepts that come out of the new proposed Stark rules from July 2nd are as follows:
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