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5 Things Washington: Q&A w/Rep. Bateman, ACA subsidy expansion, Overdose deaths accelerate DJ Wilson | Feb 25, 2021 Share this: Our new 2021 State of Reform Federal Health Policy Conference is coming together well. We will release the full list of over 100 speakers in two weeks time ahead of our April 7-8th event. You’ll see some names you recognize from the Northwest congressional delegation there – as well as some national figures that you often see in the news. We’d love to have you register to be with us, if you can make it. So, we created a discount code that will lowe...

To embed, copy and paste the code into your website or blog: On 2 December 2020, the U.S. Department of Health and Human Services’ (HHS) issued two Final Rules in conjunction with its “Regulatory Sprint to Coordinated Care,” which will markedly change the regulatory fraud and abuse landscape for “value-based” arrangements: The HHS Office of the Inspector General (OIG) published a Final Rule that introduces new safe harbor protections under the federal Anti-Kickback Statute (AKS) for certain coordinated care and risk-sharing value-based arrangements between or among clinicians, provi...

Predictions in the current antitrust, regulatory and legislative environments are hard – there is just too much happening. The better insights might be reached by thinking through what the bigger questions might be — for example, some things to think about as we approach 2021 and contemplate where a new administration in Washington and evolving antitrust enforcement regimes and priorities will take the health care industry... * Will the FTC continue to pursue health system and hospital mergers and affiliations aggressively, as it did in 2020? Will its loss in the Eastern District of Penns...

The Situation: The Office of Inspector General ("OIG") recently modified the personal services and management contracts safe harbor of the federal Anti-Kickback Statute ("AKS"). These ...

“Full Financial Risk” A. Overview of Key Safe Harbors and Exceptions An important initial consideration is that there are multiple differing requirements between corresponding Stark Law exceptions and AKS safe harbors. Stakeholders must navigate the requirements under both regulatory regimes for arrangements that potentially implicate each law. Although a number of commenters sought a unified set of requirements between Stark Law and AKS requirements, CMS and OIG rejected this approach, noting the different purposes of each law. In general, CMS provides more flexibility for Stark Law exce...