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 letter here