The Peril of Policies

  August 28, 2020 | By David Glaser, JD For the compliance-oriented, there is something rewarding about developing policies. It feels like an accomplishment, demonstrable proof of a desire to do the right thing. But speaking as a lawyer, I am convinced that most policies hurt, rather than help, the organization that adopts them. There…

Changes to Stark May Require Tweaks to the Physician Compensation Formula

  January 8, 2021 | By David Glaser In early December, the Centers for Medicare and Medicaid Services (CMS) issued new rules that dramatically revise the Physician Self-Referral Law, commonly called the “Stark law” after Pete Stark, the Congressman credited with introducing it. While many of the changes loosen the law’s restrictions, focused particularly on…