CMS and Sub-Regulatory Guidance: Is There a Compliance Risk? |
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This article explains why federal agencies use sub-regulatory guidance, describes how the Centers for Medicare and Medicaid Services (CMS), in particular, has used sub-regulatory guidance in the Medicare Advantage program, identifies key considerations in determining whether CMS sub-regulatory guidance creates legally enforceable obligations upon Medicare health plans, and offers several reasons why efforts to comply with sub-regulatory guidance might have a useful impact on an organization. Read full article. |
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