CMS Has Spoken: FMV and Commercial Reasonableness Under the New Stark Regulations
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Tim Smith, Principal, TS Healthcare Consulting LLC.
March 29, 2021
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Understand the new definitions of fair market value (“FMV”), general market value (“GMV”), and commercial reasonableness (“CR”)
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Examine the updated criteria for determining FMV, GMV, and CR
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Apply the new framework for using and not using survey data or FMV and GMV
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Evaluate the impact of practice losses for FMV and CR purposes
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