The Physicians Advocacy Institute (PAI), of which CSMS is a part of, recently sent a letter in response to CMS' request for information on the need for modernization of "anti-kickback" laws. CSMS contributed significantly to the development of this letter and it is consistent with our previous comments to CMS regarding CMMI, APMs, stark and self-referral statutes and initiatives.

Three high-level recommendations are included in the letter:

1. Establish clear exceptions to the Statute and CMP restrictions for payment models and demonstrations and other arrangements that promote physician-led initiatives to value-based care.


2. Allow for physicians to align with other high-quality providers (clinical and non-clinical, including social support organizations) for greater coordinated care and a more holistic approach to patient care.


3. Encourage physician-patient relationships through greater patient incentives and rewards that promote and support the delivery of high-value, low-cost care and contribute towards greater coordinated care that improves outcomes.

Read the full letter here.