The Clinically-Integrated, Value-Focused World

2015 in Review and Seven Tips for 2016 and Beyond

For healthcare providers, and in particular for hospitals and physicians, 2015 was an interesting year that was full of surprising twists and zigzagging transactional trends. In the first half of the year, new legislation promised radical transformation in the way physician services are reimbursed, and also some significant changes for hospitals.

Later in the year, the Bipartisan Budget Act of 2015 brought unexpected change to the rules governing Medicare payment for off-campus outpatient hospital services, with potentially significant implications for pending transactions and future hospital expansion. In between, the United States Department of Health and Human Services (HHS) issued several potential game changing regulatory releases, including new proposed (and then finalized) changes to the Stark law regulations, significant additional new guidance on activities related to gainsharing, and also newly proposed guidance regarding participation in the 340B drug pricing program.

As 2016 progresses, physicians and hospitals face a number of significant changes. Many of the changes are a result of the aforementioned developments of 2015. Some relate to the ongoing post-Affordable Care Act evolution of value-based payments for health care services. Others relate to changes in the regulatory enforcement environment. This whitepaper provides an overview of the changes facing hospitals and their physician medical staffs, and provides some tips for hospitals seeking to navigate the new landscape, particularly as they consider clinical integration with other providers and other aligning ventures.