Category: Clinical Integration

Telemedicine IT Donations and the Anti-kickback Statute OIG Opinion 18-03

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Overview of the OIG Advisory Opinion No. 18-03 The Office of Inspector General (OIG) of the U.S. Department of Health and Human Services issued Advisory Opinion No. 18-03 regarding an arrangement in which a federally qualified health center look-alike (the “Provider”) proposes to donate informati...

Clinical Integration Health Law Practice Physician Attorney

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Clinical Integration Attorneys: Advising Providers Structuring and Operating Clinically Integrated Organizations Many providers are exploring or are in the formation stages of developing clinically integrated provider organizations.  Health care attorney John Fisher has been counseling health ca...

Joint Fee Information and Antitrust Laws – Clinical Integration

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Jointly Providing Health Care Fee Information to Payers  As health care provider networks move down the path toward clinical integration, we are often asked to provide guidance on how information can be jointly provided to payors.  The antitrust laws recognize that collective sharing of some pr...

Bundled Payment Mechanisms for Clinically Integrated Health Care Systems

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Bundled Payment and ACO Arrangements – Clinically Integrated Payment Methodologies   I recently attended a series of seminars covering the legal and business aspects of bundled payment methodologies.  This is an issue that my clinically integrated network clients are facing on a more frequent ...