A licensed pharmacist was arrested on August 17, 2021 in Chicago on charges related to his alleged sale of several authentic Centers for Disease Control and Prevention (CDC) COVID-19 vaccination cards on eBay. According to court documents, in March and April 2021, Tangtang Zhao, 34, of Chicago, sold 125 authentic CDC vaccination cards to 11 different buyers for approximately $10 per card.  Zhao was a licensed pharmacist in Illinois and was employed at Company 1, a pharmacy which distributed and administered COVID-19 vaccines at its physical locations nationwide.  As required by the CDC, Company 1 provided a CDC Vaccination Record
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In June 2021, the Centers for Medicare & Medicaid Services (“CMS”) published Advisory Opinion No. CMS-AO-2021-01 (“AO”), indicating that a physician practice could qualify as a “group practice” under the federal physician self-referral prohibitions (a.k.a. the “Stark Law”) if the practice furnishes designated health services (“DHS”) through a wholly-owned subsidiary entity that is enrolled in the Medicare program as a physician practice. GENERAL RULE As a general matter, the Stark Law prohibits a physician from referring Medicare beneficiaries to an entity for the furnishing of DHS if the physician (or one of their immediate family members) has a financial relationship
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