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CodeMap® 05/03/2013: EMR and EHR Safe Harbor Proposals

CodeMap® Compliance Briefing: May 3, 2013


Editor's Welcome:

On April 10, 2013, the Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) published very similar proposed rules that may revise the Stark Law exception and the Anti-Kickback Law Safe Harbor concerning the provision of EHR and EMR items and services. Since 2006, providers have been able to provide these items and services as long as they complied with the relevant requirements of the Stark Law exception and the Safe Harbor. This week we examine these requirements, as well as the recently proposed changes that may significantly diminish labs' ability to create such financial arrangements with referring customers. As always, please send any questions, comments, or suggestions via email.

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* The responsibility for the content of any "National Correct Coding Policy" included in this product is with the Centers for Medicare and Medicaid Services and no endorsement by the AMA is intended or should be implied. The AMA disclaims responsibility for any consequences or liability attributable to or related to any use, nonuse, or interpretation of information contained in this product.



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