Practices: Managed Care/Clinical Integration

Ungaretti & Harris healthcare lawyers serve as legal and business advisors to managed care provider entities, helping them improve their market position through innovative approaches with healthcare payors and other entities. We have designed and implemented numerous provider-based integration structures—including PHOs, IPAs, MSOs and employer/healthcare provider alliances—while providing guidance regarding the Stark Law, Medicare fraud and abuse, antitrust, licensure and insurance law requirements.

Ungaretti & Harris healthcare lawyers are particularly experienced in the design, development and implementation of clinical integration programs that allow integrated providers to cooperate on clinical quality initiatives while collectively negotiating with payors for enhanced reimbursement.

We have implemented clinical integration programs for health systems, independent practice associations, physician-hospital organizations and participating providers across the country. Our lawyers are knowledgeable on Federal Trade Commission ("FTC") and Department of Justice clinical integration guidance, and are currently seeking a FTC Advisory Opinion on a clinical integration program.

In addition to advising on and developing all necessary agreements, documents, policies, procedures and infrastructure necessary to support clinical integration, our lawyers are familiar with the information technology systems essential to support clinically integrated programs. We help clients establish systems to facilitate reporting of patient data to demonstrate compliance with evidence-based performance measurements, clinical protocols, disease management programs, patient registries, PQRI measures and other quality indicators.

Clinically integrated entities that can demonstrate sufficient ancillarity are legally authorized to utilize single-signature payor contracting methods. Ungaretti & Harris lawyers can help clients transition from less effective messenger model contracting methodologies to clinical integration. This enables them to collectively negotiate payor contracts with competitive fee schedules and increased potential for pay-for-performance participation, including increased reimbursement through the Medicare Physician Quality Reporting Initiative and commercial health plan bonus methodologies.