New Opportunities in Value-Based Care Part 5: How to Create a Full Financial Risk Value-Based Enterprise

Nelson Mullins Riley & Scarborough LLP
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This is the fifth 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.

The Stark Full Financial Risk Arrangement exception protects participants in a value-based arrangement with a value-based enterprise that has assumed “full financial risk.” This risk must be on a prospective basis, for the cost of all patient care items and services covered by the applicable payor for each patient in the target patient population, and for a specified period of time.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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