CMS Opines That Stark Isnt That Stark Advisory Opinion Guidance
A CMS advisory opinion [Advisory Opinion No. CMS-AO-2021-01] issued in June 2021 provides guidance that a parent-subsidiary medical practice entity structure in which the subsidiaries themselves don\u2019t qualify as \u201cgroup practices\u201d under Stark can, in total, qualify as a \u201cgroup\u201d.