The Centers for Medicare & Medicaid Services (CMS) has published a final rule with comment period establishing sweeping disclosure and monitoring obligations for providers and suppliers enrolled or enrolling in federal health programs, and expanding CMS's authority to deny or revoke enrollment status. In particular, the rule establishes an expansive new "affiliations" disclosure requirement that allows CMS to identify individuals and organizations that, according to CMS, pose an undue risk of fraud, waste or abuse based on their relationships (i.e., "affiliations") with other enrolled or previously enrolled entities. While the rule is scheduled to go into effect November 4, 2019, CMS is accepting public comments until that date. A Reed Smith analysis of the rule highlighting key topics for comments is available here.
This article is presented for informational purposes only and is not intended to constitute legal advice.
