On September 5, 2007, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited third phase of its final rulemaking (the Phase III rule) regarding the federal physician self-referral prohibition, known as the "Stark law." The amendments reflected in the Phase III rule go into effect on December 4, 2007. The Phase III rule contains some revisions that will be welcomed by physicians and entities furnishing designated health services subject to the self-referral prohibition (designated health services (DHS) entities). Other provisions of the Phase III rule are likely to prove problematic.
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