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Compliance for integrated provider-payers

Randi E. Seigel ( is a Partner in the New York City office and Christopher C. Rundell ( is an Associate in the Chicago office of Manatt, Phelps & Phillips LLP (Manatt Health).

As providers and payers increasingly align to offer integrated products, the bright line that once existed between the two has blurred. While there are considerable benefits to integration, integration presents novel compliance challenges as the parties design and operate their communal ventures. Various federal statutes, regulations, and guidance pose myriad issues for the unwary; as integrated provider-payers share risk, exchange data, produce collaborative marketing, and internally refer beneficiaries, the parties must stay aware of and manage the risks unique to such partnerships.

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