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AAMC Submits Comments to OIG on Antikickback Statute and CMP

October 26, 2018—The AAMC Oct. 26 submitted comments to the Health and Human Services Office of Inspector General on ways to modify or add regulatory safe harbors and exceptions for the anti-kickback statute and beneficiary inducement civil monetary penalty to foster arrangements that promote care coordination and advance the delivery of value-based care.

The AAMC recommends that a new value-based “alternative payment model” safe harbor be created to allow remuneration that is provided under such arrangements. It should protect incentive payments, shared savings payments, and support provided to assist with implementation of the clinical integration arrangement.

In addition, the AAMC recommends a safe harbor for patient assistance that promotes access to health care, such as provision of home monitoring devices, telemedicine capability, and post-discharge contacts by clinicians. These services should also include nonclinical care related to the patient’s medical care, such as social services, dietary counseling, and provision of food.

Comments are due Oct. 26.


Gayle Lee
Director, Physician Payment & Quality
Telephone: 202-741-6429


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806