On February 17, 2009, the American Hospital Association, Association of American Medical Colleges and Federation of American Hospitals submitted a comment letter to CMS recommending two new exceptions to the physician self-referral law - exceptions for incentive payment and shared-savings programs. At the same time, the hospital groups also submitted a letter to the OIG asking for formal withdrawal of the 1999 Special Bulletin regarding gainsharing arrangements. The letters address CMS final rule with comment
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