Care Coordination, Clinical Integration, Group Practices, and Research: Designing Healthcare Provider Incentives
Recording of a 90-minute CLE video webinar with Q&A
This CLE course will guide healthcare counsel and advisers on the emerging trends in financial incentives for physicians and other providers and the pitfalls in properly documenting, structuring, and implementing them. The panel will review the relevant changes to the Stark Law and Anti-Kickback Statute regulations, the implications for physician incentives, and the different regulatory structures under which healthcare organizations must operate in 2024 and forward.
Outline
- Emerging trends and focus areas for healthcare provider financial incentives, including new "care team" bonuses allowed for group practices and rules about group practice protection for value-based enterprise profits
- Old and new pitfalls in documentation, structure, and implementation, as evidenced through case law and regulatory guidance
- Commercial reasonableness and FMV after Stark Law and AKS Final Rules, including how these concepts and their importance have changed (and also how they haven't changed)
- Best practices for avoiding pitfalls in the design and structuring of incentive compensation arrangements
Benefits
The panel will review these and other key issues:
- What are the recent trends in physician incentives?
- What steps can healthcare advisers take to ensure regulatory compliance when structuring physician incentives?
- What are the implications for compliance with the Stark Law, the AKS, tax exemption and public entity laws, and other laws and regulations?
Faculty
Andrea M. Ferrari, JD, MPH
Principal and General Counsel
Pinnacle Healthcare Consulting
Ms. Ferrari has more than 25 years of experience in the healthcare industry in various counsel, consulting and... | Read More
Ms. Ferrari has more than 25 years of experience in the healthcare industry in various counsel, consulting and leadership roles. She serves clients inside and outside of Pinnacle, providing assistance with compliance strategy, risk management, due diligence, investigations, and litigation.
Her practice experience is national in scope and includes providing transactional, operational, governance, and dispute resolution support for a broad array of nonprofit, for-profit, and governmental clients, including hospitals and health systems, physicians and physician groups, clinical laboratories, and pharmaceutical and medical device vendors, distributors, and manufacturers. She has assisted clients with structuring, documenting, managing, and, when appropriate, defending financial arrangements involving healthcare providers, often with attention to requirements and implications of the Stark Law, Anti-kickback Statute, False Claims Act, non-profit tax regulations, Foreign Corrupt Practices Act and/or the various state laws concerning billing, payment and corporate practice of medicine. Her work has included assisting clients with mergers and acquisitions, affiliations, joint ventures, public-private partnerships, enterprise-level compliance programs, and healthcare workforce recruitment and management arrangements, including significant incentive, independent contractor, and employment arrangements that exceed $1 million in annual compensation. Her work has also included outside general and special counsel services for healthcare clients, focusing on their contracting and compensation practices.
CloseVonne M. Jacobs
Of Counsel
Hall Render Killian Heath & Lyman
Ms. Jacobs focuses her practice in the area of healthcare transactions. Calling upon her years of dedicated experience,... | Read More
Ms. Jacobs focuses her practice in the area of healthcare transactions. Calling upon her years of dedicated experience, she provides practical, pragmatic advice to help her clients achieve their strategic goals. Within the highly regulated health care industry, Ms. Jacobs advises clients, including hospitals, health systems, AMCs and large physician groups, on transactions. She serves as a regulatory adviser, providing fraud and abuse analysis in the context of a deal and ensuring her clients remain compliant with the regulations that govern health care transactions.
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