JD Supra August 5, 2022
Many health system leaders are developing health equity plans to participate in new value-based care payment models. The new ACO REACH payment model from the Center for Medicare and Medicaid Innovation (CMMI) has increased these efforts.
It may seem reasonable to repurpose annual Community Needs Assessments (CNA), or Impact reports to be compliant with the new regulations. Doing so, however, misconstrues the CMS’ wording and intent and may lead to additional regulatory scrutiny and potential payment reductions. Pleas of confusion over vague CMS wording hasn’t stopped them from levying fines. CMS has issued fines for lack of compliance with new price transparency regulations despite perceived lack of clarity and intent. It would not surprise us to see similar penalties...
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