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May 1, 2023

Consider Three-Step Process to Pivot to Post-PHE Loss of Stark Waivers

Report on Medicare Compliance

In Volume 32, No. 16 of the Report on Medicare Compliance, which was published on April 24, 2023, Nelson Mullins partner Bob Wade was featured in an article that was published in the report. Wade, who is based in Nashville, Tennessee, offered his thoughts on Stark waivers and how they provided hospitals a berth in their compensation relationships. 

"If a portion is because of COVID, that has to be taken off the table,” said Wade. He also said that, "if hospitals are able to justify continuing the above fair-market value compensation for other reasons, it may go back on the table even though it’s no longer considered a COVID-19 differential."

Read the full report here.