Lexology January 16, 2025
Value-based care (VBC) is a health care delivery model that has grown increasingly common in recent years. Perhaps unsurprisingly, this growth seems to have attracted the attention of government enforcement agencies. In September 2024, the Department of Justice (DOJ) announced a large False Claims Act (FCA) settlement with a VBC primary care practice. In December 2024, the Office of Inspector General for the Department of Health and Human Services (OIG) issued a Special Fraud Alert addressing enforcement efforts implicating certain VBC business arrangements. VBC stakeholders should take note of these developments and the government’s apparent focus on patient recruitment and referral arrangements. As health care delivery models continue to shift from traditional fee-for-service to VBC, we expect this emerging enforcement...
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