CMS issued explanatory guidance in reference to blanket waivers of the sanctions under 1877(g) of the Social Security Act. The guidance answered lingering questions about rental compensation arrangements that would allow for repayment to occur beyond the end of the term of the emergency waivers, such as emergency rent abatement arrangements.
The explanatory guidance issued by CMS provides that parties who have negotiated real estate arrangements prior to the termination of the blanket waivers, but that continue beyond the termination of the blanket waivers, will not be subject to penalties under the Stark Law. Read our full article here for more information on rent abatement and physician arrangement compliance during and after the COVID-19 pandemic: https://bit.ly/31ZDhtR.
