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CMS Finalizes The Increasing Organ Transplant Access Model

The Increasing Organ Transplant Access Model ("IOTA Model") introduces mandatory financial incentives and penalties for selected kidney transplant hospitals....more

HHS Finalizes New AKS Safe Harbors for Patient Engagement and CMS-Sponsored Arrangements

The Situation: As health care providers transition to value-based care models, they have often been forced to rely on safe harbors under the Anti-Kickback Statute, or AKS, that were never designed with value-based payment...more

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