This is the second in a five-part series discussing the new Value-Based Regulations adopted last year by the Centers for Medicare & Medicaid Services and the Office of Inspector General.

Creating a “value-based enterprise” is the key first step necessary to satisfy the requirements of a Stark value-based exception or an Anti-Kickback Statute value-based safe harbor.

A value-based enterprise is a network of participants (including clinicians, providers, and suppliers) that have agreed to collaborate with respect to a target patient population, with a goal towards increasing efficiencies in the delivery of care and improving outcomes for that patient population.