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Coordinated Care and the Regulatory Response to Gainsharing (2022 Health Law Institute Session)

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---------- CLE 1 sub/0 eth PRICE Regular: $79.00
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CMS and OIG ”Regulatory Sprint to Coordinated Care” resulted in each agency’s publication of Value-Based Regulations on December 2, 2020, with a January 19,  2021, effective date.  OIG and CMS were pretty consistent when developing Value Based definitions and Value Based Rules where the physician-value based participants are placed at full financial risk, or at meaningful downside financial risk.   However most hospitals were hoping for clarification and consistency when they enter into gainsharing and various other value-based arrangements where the physicians were not at financial risk.  Unfortunately, here CMS and OIG issued very different rules. For example,  OIG limits its value-based safe harbors where physicians are not placed at financial to in-kind remuneration while the Stark Value Based rules apply to both cash and in-kind remuneration.  OIG did however amend the personal services and management contracts safe harbor to include outcomes-based payment arrangements, which permits cash remuneration, but only under certain circumstances.  This lecture will discuss the similarities and differences in CMS and OIG’s approach to non-risk arrangements and discuss how to how proceed.

Recorded at the Health Law Institute in March 2022.

Practice Areas


Henry M. Casale Esq. Horty Springer & Mattern PC
Faculty may vary by location.
PBI reserves the right to substitute speakers at all programs.
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