AJMC December 12, 2025
Key Takeaways
- Self-insured employers face legal challenges in adopting value-based models, including ERISA fiduciary duties, HIPAA restrictions, and antitrust concerns.
- Standardized data definitions and performance metrics are essential for successful value-based contracting, with CMS data sets offering a viable framework.
- Legal frameworks like shared savings agreements and bundled payments can aid the transition from fee-for-service to value-based care.
- Aligning with CMS data sets and federal guidance can enhance compliance and reduce risks for self-insured employers in value-based care models.
Self-insured employers face regulatory challenges when adopting value-based contracts, requiring careful data governance, standardized metrics, and legal frameworks to align with federal value-based care models.
The transition from fee-for-service (FFS) reimbursement to value-based models has been a priority in...







