On October 24, 2019, the American Health Lawyers Association's Physician Organization Practice Group published a bulletin titled "CMS and OIG Publish Proposed Rule Modifying Anti-KIckback Safe Harbors and Stark Law Exceptions Related to Shift Away from Fee-For-Service Reimbursement" which was authored by the firm's principal Adam Walters. The bulletin provided an overview of the proposed rule issued on October 9, 2019