January, 2022

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Health Care E-Note January 2022

Burr Forman

The Federal No Surprises Act (the “Act”) became fully effective on January 1, 2022. 22-01: A “Facts and Circumstances” Paradigm. Like the proposed arrangement described in Advisory Opinion 20-01, many health care “arrangements” do not meet the requirements of the AKS safe harbors. HELPFUL HINTS.