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CMS Opines That Stark Isn’t That Stark – Advisory Opinion Guidance on a Parent-Subsidiary Practice Model That’s Still a Single Group Practice
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A CMS advisory opinion [Advisory Opinion No. CMS-AO-2021-01] issued in June 2021 provides guidance that a parent-subsidiary medical practice entity structure in which the subsidiaries themselves don’t qualify as “group practices” under Stark can, in total, qualify as a “group”.
