Category Archives: Clinical Integration

Physician Autonomy in the Value-Based Care Era: Legal and Operational Priorities for Health Care Providers

Topics: value-based care compliance, physician autonomy, health care provider legal issues, Stark Law compliance, Anti-Kickback Statute compliance, physician compensation arrangements, value-based care contracts, health care compliance counsel, medical staff governance, accountable care organizations, provider reimbursement strategy, health care fraud and … Continue reading →

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ACO Primary Care Exclusivity Requirement – Not As Broad As Some Believe

By John Fisher, JD, CHC, CCEP Client Alert – MSSP ACO Participant Exclusivity Remains Narrow and Assignment-Based Updated July 10, 2026 Bottom line: MSSP exclusivity remains narrow and assignment-based. Organizations should focus compliance efforts on the TINs and claims that … Continue reading →

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OIG Advisory Opinions on Gainsharing Arrangements Since 2018

By Fisher, JD, CHC, CCEP Client Alert: OIG Advisory Opinions on Gainsharing Arrangements Since 2018 Introduction to Gainsharing Arrangements As hospitals, health systems, and physician groups continue to pursue value-based care strategies, gainsharing arrangements remain an important—but highly regulated—tool for … Continue reading →

Posted in Anesthesiologists, Clinical Integration, Fraud and Abuse, Health Care Contracting, Health Law Practice, Hospital Issues, Medicare and Medicaid, Medicare and Medicaid Reimbursement, Physician Contracting and Alignment, Physician Issues, Reimbursement & Payment Practices, Reimbursement Issues, Stark Law and Anti-Kickback Issues | Comments Off on OIG Advisory Opinions on Gainsharing Arrangements Since 2018

Health Law Firm Opens Green Bay Office

By Fisher, JD, CHC, CCEP <   Health Care Attorney John Fisher Announces Virtual Legal Services for Green Bay, Menominee, Appleton, Oshkosh, and the Greater Fox Valley Attorney John Fisher, a health care lawyer with more than 30 years of … Continue reading →

Posted in Ambulatory Surgery Centers, Anesthesiologists, Antitrust in Healthcare, Behavioral Health, Clinical Integration, Consierge & Cash-Based Practices, Dental Practice Issues, Fraud and Abuse, Health Care Contracting, Health Law Practice, HIPAA - Health Information Privacy, Home Health, Hospital Issues, Long Term Care, Medical Staff Organization & Structure, Medicare and Medicaid, Medicare and Medicaid Reimbursement, Physician Contracting and Alignment, Physician Issues, Physician-Owned Hospitals, Radiology Issues, Reimbursement & Payment Practices, Self Disclosure Protocols, Stark Law and Anti-Kickback Issues, Telemedicine, Wisconsin Health Laws, Wisconsin Hospitals, Wisconsin Long Term Care, Wisconsin Physician Issues | Comments Off on Health Law Firm Opens Green Bay Office

MSSP Contracting Rules Create Operational and Revenue Risk for ACOs

For Health System and ACO Executives | Medicare Shared Savings Program Current as of: July 2026 Executive Takeaway: Current MSSP regulations at 42 C.F.R. § 425.116 make ACO contracting infrastructure an executive-level compliance and revenue issue. CMS requires ACOs to … Continue reading →

Posted in Clinical Integration, Compliance Issues, Hospital Issues, Managed Care Contracting, Medical Staff Organization & Structure, Medicare and Medicaid Reimbursement, Physician Issues | Comments Off on MSSP Contracting Rules Create Operational and Revenue Risk for ACOs

CMS Releases Final Rules Under Medicare Shared Savings Program

By Fisher, JD, CHC, CCEP MSSP Final Rules Revision ACO Requirements Under Shared Savings Program – 2016 Revised MSSP Regulations Issues On June 10, just in time for my birthday (thanks CMS), the Centers for Medicare & Medicaid Services (CMS) … Continue reading →

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Bundled Payment Arrangements for Clinically Integrated Networks

By John Fisher, JD, CHC, CCEP Bundled Payment and ACO Arrangements – Clinically Integrated Payment Methodologies Overview of Bundled Payment Bundled payment represents a significant shift in healthcare reimbursement models, aiming to improve efficiency and quality while controlling costs. Under … Continue reading →

Posted in Accountable Care Organizations, Antitrust in Healthcare, Clinical Integration, Managed Care Contracting, Medicare and Medicaid Reimbursement, Reimbursement & Payment Practices, Uncategorized | Tagged , , | Comments Off on Bundled Payment Arrangements for Clinically Integrated Networks

Population Health Management and Clinical Integration

By John Fisher, JD, CHC, CCEP Population Health Management and Clinical Integration June 13, 2016 Population Health Management and Clinical Integration: Structural Foundations of a Reformed Health Care Delivery System Abstract Population health management and clinical integration have emerged as … Continue reading →

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Clinical Integration Readiness – Determining Organizational Readiness to Clinically Integration

Is Your Organization Ready to Build a Clinically Integrated Network? January 26, 2016 Start with the Right Readiness Assessment Clinically integrated networks can help health systems, hospitals, and physician organizations align around better care, stronger quality performance, and more efficient … Continue reading →

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Clinically Integrated Networks – Fee Sharing Procedures

By John Fisher, JD, CHC, CCEP 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 … Continue reading →

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