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Stark Law and Anti-Kickback Statute Final Rules

Tuesday, February 23, 2021 @ 12:00 pm - 1:30 pm

Exploring the 2020 changes to fraud and abuse laws.

On November 20, 2020 the Centers for Medicare and Medicaid Services (CMS) and the Department of Health and Human Services Office of Inspector General (HHS-OIG) issued long-awaited final rules to “modernize and clarify” the regulations that interpret the Medicare Physician Self-Referral Law (Stark Law) and to modify the Federal Anti-Kickback Statute (AKS).

Please join us for a presentation of these important updates to fraud and abuse laws from Gray Reed attorneys Jenny Givens and Darrell Armer .



Darrell Armer
Dallas Managing Partner
Gray Reed Attorneys & Counselors

Jenny G. Givens
Gray Reed Attorneys & Counselors

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Speakers’ Bios:

An experienced dealmaker and strategic advisor for a diverse group of healthcare clients, Darrell Armer focuses his practice on structuring complex commercial transactions that not only achieve his clients’ business goals, but also minimize risk within strict regulatory frameworks. Leader of the Healthcare Transactions Practice Group, he has over 20 years of experience managing all aspects of the organization, reorganization, funding, operation and merger/acquisition of a variety of providers, including hospitals, ambulatory surgery centers, physical therapy companies, diagnostic imaging centers, medical and dental practices, and home health agencies, as well as various provider networks. He is Board Certified in Health Law by the Texas Board of Legal Specialization.

Darrell has negotiated and structured numerous mergers and acquisitions of healthcare providers on behalf of both sellers and buyers. This unique experience working on both sides of the deal helps Darrell anticipate many issues that typically arise and resolve them proactively before they can impede negotiations or break the deal altogether. Darrell also serves as outside general counsel for many of his clients, guiding them through a variety of operational and administrative matters, including Medicare/Medicaid and other third party reimbursement and appeals, licensure issues with state boards, cyber security and related breaches, vendor contracts plus much more.

Keeping clients out of trouble is also a substantial part of Darrell’s practice. He helps clients maintain compliance with all federal and state regulations that impact entity structuring, commercial transactions and day-to-day operations, particularly the Stark Law and the Anti-Kickback Statute, HIPAA and other privacy laws, and antitrust considerations. Darrell also plays a significant role in protecting clients when they’re facing potential civil or criminal liability in government investigations or litigation involving alleged fraud or other regulatory violations. He works hand-in-hand with the firm’s white-collar lawyers, providing valuable insight on the substantive regulatory issues involved to ensure that clients achieve the best outcome possible.


Healthcare providers trust Jenny Givens to help them navigate the numerous regulatory frameworks impacting their businesses and to guide them through a variety of operational, privacy and corporate matters. She works with a wide range of providers with operations primarily in Texas but also in many states across the country, including hospitals, physician entities, ambulatory surgery centers, pharmacies, laboratories, neuromonitoring facilities plus many more. Jenny is Board Certified in Health Law by the Texas Board of Legal Specialization and Certified in Healthcare Compliance by the Compliance Certification Board.

Jenny is the go-to advisor for healthcare providers that need strategic guidance on how regulatory compliance interacts with their everyday operations and long-term business planning. She has substantial experience in developing proactive policies and corrective action plans concerning several issues, including fraud and abuse, the Stark Law, the Anti-Kickback Statute, HIPAA, EMTALA, licensure and certification, patient overflow and billing and reimbursement. Jenny also helps clients with a variety of transactional and corporate matters, ranging from employment contracts and coverage agreements to management services contracts and entity formation.

Before joining the firm, Jenny held in-house positions at Texas Scottish Rite Hospital for Children and City of Hope National Medical Center in Pasadena, California, where she handled a variety of transactional and compliance matters. Prior to entering law school, Jenny served as an assistant administrator for a community hospital in Los Angeles where she worked with medical staff committees, participated in all executive team committees and was responsible for strategic planning, service quality, licensing and accreditation activities and day-to-day operations of the hospital’s ancillary services.

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Tuesday, February 23, 2021
12:00 pm - 1:30 pm