ACC Prioritizes Stark Law and Anti-Kickback Statute Modernization

On Dec. 23, ACC submitted comments commending the Centers for Medicare and Medicaid Services (CMS) for recognizing the need to update regulations on the physician self-referral law ("Stark Law") to allow for value-based payment arrangements as part of the Regulatory Sprint to Coordinated Care. While supporting some proposed changes, the ACC noted that the regulations still remain confusing and encouraged CMS to ensure that "complexity does not stand in the way of meaningful change." The comments also highlight the need to transition to value-based care, and note that ongoing efforts should include supporting physicians "in the movement to value-based care through the development of clinician-led payment models."

Also on Dec. 23, ACC submitted comments to the U.S. Department of Health and Human Services Office of the Inspector General regarding the Anti-Kickback Statute regulations, "supporting the concept of an expanded personal services safe harbor for outcomes-based payments." However, as the letter expands, "to be effective it must be coordinated with the Stark exception for value-based arrangements." The College encouraged both CMS and the OIG to continue efforts to reduce the regulatory burden of the Stark Law and Anti-Kickback Statute regulations to support innovative delivery models and to align incentives for care coordination to better encourage team-based care.

ACC's Advocacy team has been diligently working to support a widespread transition to modern, value-based care models, incentivizing collaboration between hospitals, providers, and physicians to deliver high-quality and patient-centered care. Moving forward, the College will continue to monitor and provide comments on related legislation and will continue to provide education on the transition to value-based care. Learn more at

Keywords: ACC Advocacy, Medicare

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