Clinical Integration and ACO Alert 

News and Information from Broad and Cassel's Health Law Practice Group

July 2014
Volume 4, Issue 4
Practice Group Update

Fourth Annual Broad and Cassel Health Forum 


Friday, September 12, 2014

Noon - 5:30 pm

Seminole Hard Rock Hotel & Casino

Hollywood, FL



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Mike Segal headshot  

Mike Segal


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 Stephen Siegel  

 Stephen Siegel 

Of Counsel

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Christine Burke Worthen

Of Counsel

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Hannah Levinson


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Shachi Mankodi 


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Mankodi and Levinson Published in Compliance Today Magazine 
Shachi Mankodi and Hannah Levinson, associates in our Fort Lauderdale office, were published in the June issue of the Health Care Compliance Association's Compliance Today magazine (HCCA).


Please click here to view their article, "Expanding protection for whistleblowers."

To our clients and friends:


We are starting to see real movement throughout Florida towards consolidation, clinical integration and, in some cases, population health. 


Consolidations continue to occur among medical groups, hospitals acquiring or contracting with medical groups, and the formation of large networks, often including one or more hospitals, their employed physicians, and independent physicians.  The networks are attempting to clinically integrate as rapidly as possible so that they can contract without anti-trust risk.  We are currently involved in several of these projects.


Medicaid moves to third party contracting in October, which is just around the corner.  It seems that hospitals, managed care plans, and physician groups and networks are all scrambling to get ready.  No one really knows how this is ultimately going to play out, but one thing is for sure - beginning in October the Medicaid risk will begin
start to switch dramatically.


In truth, for health care people like myself, these times are very exciting.  All I can say is - BRING IT ON!  Hopefully the articles in this edition of our Clinical Integration Alert will provide you with some useful information and ideas. Enjoy!


Mike Segal

Health Law Practice Group Chair

Broad and Cassel

Upcoming Speaking Engagements
Imperato to speak at SCCE 13th Annual Compliance & Ethics Institute

Gabriel Imperato, managing partner of Broad and Cassel's Fort Lauderdale office and co-chair of the firm's White Collar Defense and Compliance Practice Group, will be a featured speaker at the Society of Corporate Compliance & Ethics (SCCE) 2014 Compliance & Ethics Institute. The conference will take place September 14-17, 2014 at the Hyatt Regency Chicago in Chicago, IL and is the primary education and networking event for professionals working in the compliance and ethics industry around the world. For registration and additional conference information, please click here. 

OIG Issues Special Fraud Alert Focusing on Laboratory Payments to Referring Physicians

By: Stephen H. Siegel, Esq.


On June 25, 2014, the HHS- Office of Inspector General ("OIG") issued its "Special Fraud Alert: Laboratory Payments to Referring Physicians." The OIG focused on blood-specimen collection, processing, and packaging arrangements, as well as so-called registry payments.  In addition, the OIG provided guidance that is relevant to all compensation arrangements involving parties in the healthcare industry.


Please click here to continue reading the article.    

Legal Considerations in Negotiating ACO Contracts: The New World of Risk Assumption, Enterprise Data Analytics, and Population Health Management

By: Christine Burke Worthen


With the Centers for Medicare and Medicaid Services' (CMS') Medicare Shared Savings Program (MSSP) and Pioneer Accountable Care Organization (Pioneer ACO or Pioneer) (collectively, CMS Programs) well underway, insurance companies, providers, and even self-funded employer plans are looking to leverage the movement away from fee-for-service to value-based reimbursement in an effort to transform the health care delivery system and provide high-quality care at lower costs.


Please click here to continue reading.

 About Us
With more than 20 attorneys and a full complement of support staff, Broad and Cassel's Health Law Practice Group is intimately aware of the complex issues faced by health care providers, suppliers and consumers. 
Broad and Cassel has more lawyers certified in Health Law by the Florida Bar Board of Legal Specialization & Education than any other firm in the state. The group holds a collective Band One ranking with Chambers USA: A Guide to America's Leading Business Lawyers, the highest Chambers award possible. Additionally, our individual attorneys are continually recognized both locally and nationally for their knowledge and experience.
Fundamental changes to the nation's health care delivery system are occurring at an accelerated rate, requiring those in the industry to establish and refine their practices and policies to comply with new regulations. The attorneys of our Health Law Practice Group are prepared to discuss these changes and the potential impact they will have on health care providers of all types.