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COVID-19: Frequently Asked Questions

Below are some of the most frequently asked questions CMA has received during the COVID-19 outbreak. By default, the most recent answers will appear up top. You can also filter the FAQ by category. We will update this resource regularly.

More questions? Email communications@cmadocs.org.


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Which financial relationships would create fraud and abuse concerns and thus would not be protected by the Physician Self-Referral/Stark law waivers?

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The blanket waivers require that the arrangement not create fraud and abuse concerns. Unfortunately, the blanket waivers document does not provide further guidance about how CMS may use this language to limit the applicability of the blanket waivers. Accordingly, consistent with the discussion in the COVID-19-related purposes section above, physicians should consider documenting the reasons why the arrangement was necessary, consistent with waived arrangements, and in good faith for providing services in response to COVID-19 related purpose.

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