Big Changes For The Big 3 — FMV, CR, And The Volume Or Value Standard In Physician/Hospital Relationships

On November 20, the Centers for Medicare & Medicaid Services and the Department of Health and Human Services Office of Inspector General issued a 627-page final rule which, among other changes, transitions what may be historically referred to as the “Big 2” (fair market value [FMV] and commercial reasonableness [CR]) to the “Big 3” (FMV, CR, and the volume or value/other business generated standard).