Comments on OIG Anti-Kickback Statute RFI

In this letter, the Task Force identifies areas where the HHS Office of the Inspector General can mitigate the impact of the anti-kickback statute regulations on providers and health plans participating in alternative payment models to encourage better care coordination.

Task Force Response Summary:

  1. Create new safe harbors and exceptions for risk-taking alternative payment model participants and disease management and prevention programs

  2. Define terminology regarding health care delivery and payment reform

  3. Expand sub-regulatory guidance regarding the applicability of AKS

  4. Simplify and streamline available waivers in the context of APM arrangements

  5. Align physician self-referral and anti-kickback statute regulatory definitions with the Quality Payment Program to promote consistency and reduction in regulatory burden on stakeholders

Read the full comment letter