Pay-for-Performance (P4P) and the Recent OIG Advisory Opinions on Gainsharing
Please join us for a session on:
The State of PFP Today:
A discussion of the CMS demonstration projects and private P4P Programs involving payors, hospitals, doctors, Medicare managed care plans, nursing homes, and others.
P4P Programs Without a Gainsharing Element:
Compliance of these P4P Programs with existing anti-kickback safe harbors, Stark exceptions and tax-exemption private benefit/private inurement analysis.
P4P Programs With a Gainsharing Element:
- Gainsharing programs under OIG Advisory Opinions 01-1 and 05-1 through 05-xx.
- Compliance with Civil Monetary Penalties law and Stark exceptions.
Future developments indicated by CMS demonstration programs, MedPAC recommendations, JCAHO principles, and Congressional legislation.