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.

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Have the Physician Self-Referral/Stark laws been waived during the current COVID-19 Epidemic?

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Yes. On March 13, 2020, U.S. Department of Health and Human Services Secretary Alex Azar issued a statement waiving and/or modifying the requirements under section 1135 of the Social Security Act. Afterwards, on March 30, 2020 CMS issued blanket waivers to permit certain financial relationships and referrals related to the COVID-19 pandemic that would otherwise be sanctioned by the Physician Self-Referral Law. These blanket waivers were given a retroactive effective date of March 1, 2020, and thus protect those referrals and financial relationships since that date. These blanket waivers temporarily permit payments and referrals between physicians and entities if the relationship falls into one of CMS’ stated categories during the COVID-19 pandemic, even if such an arrangement would not meet a Stark law exception. These blanket waivers are intended to give physicians more freedom and flexibility as the COVID-19 pandemic continues. Similar to other Section 1135 waivers issued in response to the COVID-19 public health emergency, these blanket waivers will terminate at the end of the public health emergency.

Sources: [HHS Waiver] [Blanket Waivers of Section 1877]

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