Trouble with images? View as a Web page.

Facebook Twitter More...
Polsinelli Shughart PC Health Care Law In the News
Attorneys

Matthew J. Murer
Practice Area Chair

Colleen M. Faddick
Practice Area Vice-Chair

Bruce A. Johnson
Practice Area Vice-Chair

Alan K. Parver
Practice Area Vice-Chair

Janice A. Anderson
Douglas K. Anning
Jane E. Arnold
Jack M. Beal
Cynthia E. Berry
Mary Beth Blake
Gerald W. Brenneman
Teresa A. Brooks
Jared O. Brooner
Anika D. Clifton
Lawrence C. Conn
Anne M. Cooper
Lauren P. DeSantis-Then
S. Jay Dobbs
Thomas M. Donohoe
Cavan K. Doyle
Meredith A. Duncan
Erin Fleming Dunlap
Fredric J. Entin
Jennifer L. Evans
T. Jeffrey Fitzgerald
Michael T. Flood
Kara M. Friedman
Rebecca L. Frigy
Asher D. Funk
Randy S. Gerber
Mark H. Goran
Linas J. Grikis
Lauren Z. Groebe
Brett B. Heger
Jonathan K. Henderson
Margaret H. Hillman
Jay M. Howard
Cullin B. Hughes
Sara V. Iams
George Jackson, III
Lindsay R. Kessler
Joan B. Killgore
Anne L. Kleindienst
Chad K. Knight
Sarah R. Kocher
Dana M. Lach
Jason T. Lundy
Ryan M. McAteer
Jane K. McCahill
Ann C. McCullough
Ryan J. Mize
Aileen T. Murphy
Hannah L. Neshek
Gerald A. Niederman
Edward F. Novak
Thomas P. O'Donnell
Aaron E. Perry
Mitchell D. Raup
Daniel S. Reinberg
Donna J. Ruzicka
Charles P. Sheets
Kathryn M. Stalmack
Leah Mendelsohn Stone
Chad C. Stout
Steven K. Stranne
William E. Swart
Tennille A. Syrstad
Emily C. Tremmel
Andrew B. Turk
Joseph T. Van Leer
Andrew J. Voss
Joshua M. Weaver
Emily Wey
Mark R. Woodbury
Janet E. Zeigler

 

Additional Health Care
Professionals


Julius W. Hobson, Jr.
Harry Sporidis

To learn more about our
Health Care practice,
click here.


January 2013

 

A Polsinelli Shughart Update:

OIG Issues Advisory Opinion on Co-Management Incentive Compensation Arrangement

 

On January 7, 2012, the OIG posted Advisory Opinion No. 12-22 to address a co-management arrangement between a hospital and physicians that is designed to align incentives by offering compensation based on quality, service, and cost saving measures. The OIG concluded that the arrangement could constitute improper payment to either reduce or limit services or induce referrals under the CMP Law, warranting civil monetary penalties or Anti-Kickback Statute sanctions; however, the OIG would not impose any sanctions due to several safeguards in the arrangement.

Co-management arrangements are frequently used to align and reward physicians for assisting the hospital in managing a service line and often include incentive compensation to improve the service line's quality and efficiency. Although co-management arrangements are widely used in the industry, and the OIG has previously opined on numerous gainsharing arrangements, Advisory Opinion No. 12-22 marks the first time that the OIG evaluated a co-management arrangement.

The Advisory Opinion provides hospitals and physicians with helpful guidance as to the OIG's view of co-management arrangements, although only the requestor can rely upon it for protection. Of importance to its analysis, the OIG emphasized safeguards that have long been recognized as important to protect any type of quality or efficiency payment made by hospitals to physicians. These safeguards include (i) independent monitoring to ensure that no inappropriate changes occur to quality or referral patterns and that no inappropriate reduction in care occurs, (ii) payments that are deemed fair market value based on the services rendered by the physicians, (iii) transparency in the metrics chosen, (iv) metrics that reward improvement and not just maintenance of previous levels of achievement, and (v) continued access by the physicians to the full panoply of treatment options, reasonable limitation in the duration of the arrangement, among others. Click here for more detailed information about Advisory Opinion No. 12-22.

For More Information

For any questions, please contact:


  To learn more about our RSS feeds, click here. Click here to learn more about our RSS feeds. Click here to learn more about our RSS feeds.

Polsinelli Shughart | In the News

Headlines and Bylines from polsinelli.com


 

Polsinelli Shughart Attorney Elected Central Exchange Board Member

Polsinelli Shughart Attorneys Selected for Inclusion in 2013 Illinois Super Lawyers

Polsinelli Shughart Expands Missouri's Public Policy Practice

Podcast: Medicare Reimbursement Developments in 2012

Upcoming Webinar: Fraud and Abuse: 2012 Year in Review

Subscribe to: Polsinelli Shughart Health Reform and Related Policy News

   
 

Get more news from polsinelli.com.

   
Click here to learn more about our RSS feeds.

 

ABOUT POLSINELLI SHUGHART:

    Facebook
Connect with us on Facebook. Connect with us on Twitter. Connect with us on LinkedIn.

With more than 600 attorneys, Polsinelli Shughart is a national law firm and a recognized leader in the areas of health care, financial services, real estate, life sciences and technology, energy and business litigation. Serving corporate, institutional and individual clients, our attorneys build enduring relationships by providing practical, business-driven legal advice with a commitment to helping clients achieve their objectives. The firm can be found online at www.polsinelli.com. Polsinelli Shughart PC. In California, Polsinelli Shughart LLP.

 
       
         
         
Chicago, Dallas, Denver, Edwardsville, Jefferson City, Kansas City, Los Angeles, New York Overland Park, Phoenix, St. Joseph, St. Louis, Springfield, Topeka, Washington, D.C., Wilmington DE
 

To update your email preferences, please contact us at Interaction@polsinelli.com. To opt out of these communications, click the unsubscribe link below.

Polsinelli Shughart provides this material for informational purposes only. The material provided herein is general and is not intended to be legal advice. Nothing herein should be relied upon or used without consulting a lawyer to consider your specific circumstances, possible changes to applicable laws, rules and regulations and other legal issues. Receipt of this material does not establish an attorney-client relationship.

Polsinelli Shughart is very proud of the results we obtain for our clients, but you should know that past results do not guarantee future results; that every case is different and must be judged on its own merits; and that the choice of a lawyer is an important decision and should not be based solely upon advertisements.

Polsinelli Shughart PC. In California, Polsinelli Shughart LLP. Polsinelli Shughart® is a registered trademark of Polsinelli Shughart PC.


Copyright © 2013 Polsinelli Shughart PC ®.

 
           
Polsinelli Shughart