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Office of Inspector General
Affirms
Co-Management Agreements
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On January 7, 2012, the U.S. Department of Health and Human Services, Office of Inspector General (OIG), posted Advisory Opinion 12-22 (AO 12-22). Such opinion marked the first time the OIG directly evaluated a Clinical Co-Management Agreement (CCMA), a mechanism that serves to align both the economic and non-economic interests of hospitals and physicians. Prior to AO 12-22, hospitals and physicians could only look to OIG opinions on numerous gainsharing arrangements and only one advisory opinion, issued in 2008, addressing a pay for performance arrangement in structuring compliant CCMA's.
In AO 12-22 the OIG reviewed a CCMA between a large, rural acute care hospital and a cardiology physician group utilizing a structure consistent with Murer Consultants CCMA strategies. The OIG favorably found that the arrangement did not warrant sanctions under the Civil Monetary Penalty law and the Anti-Kickback Statute.
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