AHA Amicus Brief
AHA filed an Amicus Brief in support of Tuomey Healthcare System of Sumter, SC, which is appealing a lower court's award of more than $44 million to the federal government based on alleged violations of the Stark Law, January, 11, 2011 

AHA's Support for the Development of the Self-Referral Disclosure Protocol Required Under the PPACA
AHA letter to Secretary Kathleen Sebelius Support for the Development of the Self-Referral Disclosure Protocol Required Under the PPACA, July 16, 2010

Comment Letter
To CMS re: exception to incentive payment and shared savings program,  February 17, 2009
AHA joins AAMC and FAH in a letter to CMS in response to their additional opportunity to comment on the proposed exception to the physician self-referral law for incentive payment and shared-savings programs.

AHA Regulatory Advisory 
CMS Request for Additional comments on Proposed Exception for Incentive Payment and Shared Savings Program, Jan. 21, 2009

AHA Comment letter
AHA urges OMB to deny CMS authorization to proceed with the DFRR, Jan. 16, 2009

AHA Comment Letter on:
CMS' proposed exception to self-referral prohibition, August 27, 2008
     Text of CMS Proposed Exception for Incentive Payment and Shared Savings Programs, July 7, 2008
     CMS Solicitation of Additional Public Comments ("55 Questions"), Nov. 19, 2008    

AHA Regulatory Advisory Members Only
Medicare Inpatient PPS: The Final Rule for Fiscal Year 2009, August 18, 2008

Technical Corrections to Phase III
CMS publishes technical corrections to Phase III, Dec. 4, 2007

CMS Delays Provisions of Phase III Stark Rule
CMS publishes final rule delaying by one year certain limits affecting the compensation arrangements that academic medical centers and nonprofit "integrated health care systems" may have with affiliated physician organizations, Nov. 15, 2007

AHA Regulatory Advisory
CMS Issues Phase III Final Rule on Physician Self-Referrals, Nov. 1, 2007

AHA Comment Letter 
CMS proposal to establish a mandatory Disclosure of Financial Relationships (DFRR) reporting system for hospital relationships with physicians, Oct. 10, 2007

AHA Comment Letter
CMS' proposed changes to physician self-referral rules, Aug. 29, 2007

AHA Regulatory Advisory
CMS proposed changes to the physician self-referral or “Stark” rule, July 31, 2007

AHA Comment Letter
CMS Proposed Disclosure of Financial Relationships Report, July 16, 2007

AHA Letter
IRS Guidance on Health IT Sharing with Physicians, Nov. 15, 2006 

AHA Regulatory Advisory
Final "Stark" and Anti-Kickback Regulations on Health Information Technology, August 28, 2006 (AHA Members only)

AHA Regulatory Advisory (AHA Members Only)
Stark II and Anti-kickback Regulations, November 7, 2005

AHA Comment Letter
Physicians' Referrals to Health Care Entities with which They Have Financial Relationships (Phase II) (69 Federal Register 16054), June 24, 2004

AHA Regulatory Advisory (AHA Members Only)
CMS Issues Phase II of "Stark II" Physician Self-Referral Regulation, May 21, 2004

Exchange of letters between AHA and CMS regarding Self-Referral/Stark guidance, and related correspondence

AHA Regulatory Advisory (AHA Members Only)
HCFA Physician Self-referral Regulations, March 23, 2001


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