April 12, 2021

Volume XI, Number 102


April 09, 2021

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Podcast: CMS and OIG Final Rules for Innovating Your Value-Based Payment Program – Diagnosing Health Care

In this episode of the Diagnosing Health Care Podcast:  The Centers for Medicare & Medicaid Services (“CMS”) and the Office of Inspector General (“OIG”) of the Department of Health and Human Services have at last published their long-awaited companion final rules advancing value-based care. The rules present significant changes to the regulatory framework of the federal physician self-referral law (commonly referred to as the “Stark Law”) and to the federal health care program’s Anti-Kickback Statute, or “AKS.”

Epstein Becker Green attorneys Anjali Downs, Jennifer Michael, Lesley Yeung, and Paulina Grabczak give an overview of the final rules and point out key issues health care companies should carefully consider as they take advantage of these value-based care safe harbors and exceptions.

The Diagnosing Health Care podcast series examines the business opportunities and solutions that exist despite the high-stakes legal, policy, and regulatory issues that the health care industry faces. Listen below and subscribe on your favorite podcast platform.


©2021 Epstein Becker & Green, P.C. All rights reserved.National Law Review, Volume XI, Number 98



About this Author

Anjali N.C. Downs, Epstein Becker, Device manufacturers Lawyer, Pharmaceuticals Attorney

ANJALI N.C. DOWNS is a Member of the Firm in the Health Care and Life Sciences practice, in the firm's Washington, DC, office.

Ms. Downs represents a variety of health care and life science organizations including health systems, pharmaceutical and medical device manufacturers, pharmacies, clinical laboratories, academic medical centers, physician group practices, dialysis providers, and medical transportation providers. Her practice focuses on fraud and abuse and federal and state regulatory compliance, and she regularly:

Jennifer Michael Health Care Attorney Epstein Becker Green
Member of the Firm

JENNIFER E. MICHAEL is a Member of the Firm in the Health Care and Life Sciences practice, in the Washington, DC, office of Epstein Becker Green. She focuses her practice on federal and state fraud issues, including anti-kickback, self-referral, false claims, and regulatory compliance.

Before joining Epstein Becker Green, Ms. Michael served as Chief of the Industry Guidance Branch at the U.S. Department of Health & Human Services, Office of Counsel to the Inspector General. In that role, she led a team of attorneys responsible for interpreting and applying...

Lesley R. Yeung Epstein Becker Green Healthcare Lawyer
Member of the Firm

LESLEY R. YEUNG is a Member of the Firm in the Health Care and Life Sciences practice in the firm's Washington, DC, office. Ms. Yeung has been selected to the Washington DC Rising Stars list (2014 to 2020) in the area of Health Care.

Ms. Yeung:

  • Advises health care providers and health-related companies, financial institutions and investors of industry trends and policy developments

  • Advises hospitals, health systems and other health-related companies on legal...

Paulina Grabczak, Epstein Becker Law Firm, Healthcare Attorney

Paulina Grabczak is an Associate in the Health Care and Life Sciences practice, in the Newark office of Epstein Becker Green.

Ms. Grabczak:

  • Advises on federal and state health care fraud and abuse laws, including the Stark Law and the Anti-Kickback Statute

  • Assists with all aspects of transactional regulatory health care due diligence

  • ...