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National Intelligence Report

CMS Takes Another Look at Stark ‘Stand in the Shoes’ Rules
June 9, 2008

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Editor’s Note: The Centers for Medicare & Medicaid Services is proposing to revisit the controversial "stand in the shoes" provisions that apply to direct and indirect compensation arrangements under the Stark physician self-referral rules. The agency called for comment, to June 13, on this and several other Stark modifications in its proposed rule for the fiscal 2009 inpatient prospective payment system, issued April 30. For an analysis of the "stand in the shoes" proposal, NIR turned to attorney Robert E. Mazer, with Ober/Kaler in Baltimore, Md., who commented as follows:

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