On July 8, 2015, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule pertaining to payment policies under the Physician Fee Schedule for CY 2016 (“Proposed Rule”).1 In addition to changes to the Physician Fee Schedule and other Medicare Part B payment policies, the Proposed Rule also addressed many potential modifications to the Stark Law, including the creation of new exceptions and guidance on CMS’s interpretation of existing Stark Law exceptions.

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