Regulatory Updates to Value-Based Care Arrangement Exceptions – Stark and AKS
January 12, 2021
by Sean Weiss, Partner & VP of Compliance
I have reviewed Federal Register / Vol. 85, No. 232 / Wednesday, December 2, 2020 / Rules and Regulations specific to the Value-Based (VB) Care. I have created an 8-page summary (see link below) of what I believe to be the most impactful parts of the Final Rule, definitions, exceptions, etc. There are good examples included for what does and does not support VB arrangements. There is a (new to me) term the government uses called “lemon-dropping.” You will find this towards the end of the document.
This is a long document. It is due to the extensive nature of what HHS and OIG provided as the final rule and explanations of how they transitioned from the proposed rule. There are multiple sections of the Statue in addition to changes to the Anti-Kickback Statute (AKS). I will be working through each of these over the coming weeks. There is just a massive amount to review and summarize.
Please remember! This is a summary of the federal register and is not meant to be legal guidance or advice. For that, you need to contact your company attorney.
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