81X—$0 Physician Subsidy—Harnessing the 2021 Stark Law Update Into Sustainable, Triple-Aim Compensation Design

Wednesday, March 30th

About the Session

This session will provide a clear roadmap for physician employer organizations to adopt a compensation plan methodology that truly achieves the Triple Aim as led by the employed medical staff. This approach moves beyond the “margin for mission” philosophy of provider integration heavily relied upon over the last 25 years.

The 2021 Stark Law update allows for a new type of continuous improvement approach, whereby physicians are paid reasonably for their traditional clinical work and paid additionally for driving value. The value-based pay is conditioned on performance improvement or maintenance of clinical quality excellence.

The short-term outcome is a practical focus on a transition from volume to value (achievable even if primarily reimbursed on a fee-for-service basis). The long-term outcome is achieving a net $0 subsidy as the spread between “market” physician compensation and reimbursement is transformed from the source currently being “hospital profits” to reductions in the total cost of care either or both from a facility and payor standpoint.

Presenters will introduce the key concepts, present an adoptable compensation framework, describe how to get started, and how to monitor and manage compliance risks associated with this new type of compensation plan.

Learning Objectives:

  • Gain a functional knowledge of the new value-based Stark Law exceptions as they pertain to compensation plan design and compliance.
  • Discover how to structure physician compensation within the value-based exceptions to the Stark Law in a way that can achieve Triple Aim–type alignment.


Presented By

Eric Leafgreen, CPA

Director, Physician Compensation