Special Report - Untangling VBEs, ACOs and CINs - What to Know about CMS and OIG's Proposed Regulations - December 2019

The Centers for Medicare & Medicaid Services and the Office of Inspector General recently released notices of proposed rulemaking relating to the Stark Law and the Anti-Kickback Statute. We break down the new proposed value-based care arrangement exceptions and safe harbors, and implications for provider contracting networks such as accountable care organizations and clinically integrated networks.

On October 9, 2019, in conjunction with the US Department of Health and Human Services (HHS) Regulatory Sprint to Coordinated Care initiative, the Centers for Medicare & Medicaid Services (CMS) and the HHS Office of Inspector General (OIG) both released notices of proposed rulemaking relating to the federal physician self-referral statute (42 USC § 1395nn) and its associated regulations (42 CFR § 411.350 et seq.) (collectively, the Stark Law), and relating to the safe harbors under the federal Anti-Kickback Statute (42 USC § 1320a-7b(b)) and its associated regulations (42 CFR § 1001.952 et seq.) (collectively, AKS).

Please see full Special Report below for more information.

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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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