News & Analysis as of

Clinically Integrated Networks (CINs)

Expansion of Clinical Services at Assisted Living Sites – The New Paradigm

by Foley & Lardner LLP on

As payment reforms, such as bundled payments and Accountable Care Organizations (ACOs), drive further provider collaboration to achieve lower costs with enhanced outcomes, post- acute providers, especially assisted living...more

[Webinar] PSST! Physician Strategies & Success Tools - Nov. 4th, 2:30pm EST

by Dickinson Wright on

Join us for an informative webinar to discuss: Healthcare Contracting -- Legal Issues and Practical Considerations Clinical Integration -- ACO's, Super Groups and Other Integration Structures Hospital...more

CMS Is Considering New Stark Exceptions to Promote Clinical Integration and Value-Based Payment – Submit Your Comments By...

by Locke Lord LLP on

CMS has proposed significant changes in the Medicare physician self-referral (typically referred to as the “Stark Law”) regulations, including new compensation exceptions and several clarifications and refinements of existing...more

District Court Weighs in on Level of Integration Required to Shield Health Care Collaborations from Section 1 Scrutiny

In Medical Center at Elizabeth Place v. Premier Health Partners et. al, Case No. 12-cv-26 (S.D. Oh. Oct. 20, 2014), the Southern District of Ohio held that previously-competing health care systems who join together in a...more

Illinois Blues Won’t Let Hospitals Jointly Negotiate Unless They’re Married

by Faegre Baker Daniels on

Remember when Hollywood wouldn’t show an unmarried couple in bed together? Blue Cross-Blue Shield of Illinois is taking that approach to contract negotiations. If hospitals want to negotiate jointly with the insurer, they...more

Manatt on Medicaid: State Strategies for Integrating Physical and Behavioral Health Services in a Changing Medicaid Environment

Medicaid plays a central role in financing mental health and substance use disorder (SUD) services, accounting for 26 percent of all spending on behavioral health services in this country. Medicaid beneficiaries with...more

Norman Physician Hospital Organization — Factors Supporting Clinical Integration

by McAfee & Taft on

Clinical integration is a somewhat imprecisely defined concept in the health care industry. Lawyers and health care executives have identified components and elements of clinical integration and frequently ask how many of...more

Price Fixing and Leveraging Concerns Alleviated by Promoted Efficiencies: More FTC Guidance on Clinical Integration

by Baker Donelson on

The Federal Trade Commission (FTC) has provided additional guidance, and comfort, to physicians seeking to clinically integrate for the purpose of, among other things, jointly negotiating payor contracts. This additional...more

Clinical Integration On A Promise And A Plan Federal Trade Commission Declines To Challenge Norman PHO On Antitrust Grounds

by Polsinelli on

In This Issue: - Norman PHO - Key Conclusions - Implications for Established and Newly Forming Networks - Excerpt from Norman PHO: The Norman PHO is comprised of a single hospital system and...more

Just How Much Integration Is Enough: FTC Advisory Opinion Finally Provides Guidance For Competitors Seeking To Collaborate Or...

by Pepper Hamilton LLP on

The Federal Trade Commission (FTC) recently issued its first advisory opinion addressing clinical integration programs since the enactment of the Affordable Care Act (ACA). Without a doubt the advisory opinion is useful for...more

FTC's Norman PHO Advisory Opinion - New Clinical Integration Guidance, Same Antitrust Analysis

by Baker Donelson on

The Federal Trade Commission (FTC) provided its first guidance for clinically integrated networks since passage of the Affordable Care Act (ACA) and the joint FTC/DOJ Accountable Care Organization (ACO) Antitrust Policy...more

FTC Staff Issues Favorable Clinical Integration Advisory Opinion That It Does Not Intend to Challenge Proposed Formation of...

by King & Spalding on

On February 13, 2013, the FTC issued an advisory opinion letter that it did not plan to challenge the proposed creation of the Norman Physician Hospital Organization (“Norman PHO”)—which includes approximately 280...more

FTC Issues Another Favorable Clinical Integration Program Advisory Opinion

by McDermott Will & Emery on

In a February 13, 2013, advisory opinion, the Federal Trade Commission (FTC) Bureau of Competition stated that it has no present intention to recommend that the FTC challenge a clinical integration program (CIP) proposed by...more

FTC Issues First Clinical Integration Advisory Opinion Post-ACA

FTC staff advisory opinions are not issued all that frequently and advisory opinions regarding clinical integration are issued even less frequently. The latest advisory opinion, issued last week, is therefore noteworthy, not...more

FTC Issues Favorable Clinical Integration Advisory Opinion to Norman, Oklahoma PHO

by Mintz Levin on

Since the passage of the Affordable Care Act (ACA), much attention has been paid to the antitrust treatment of Accountable Care Organizations, provider ventures contemplated by the ACA that the Federal Trade Commission and...more

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