14th Annual Conference on Emerging Issues in Healthcare Law

American Bar Association

Event Info

  • Date:


  • Time:

    11:00 am - 12:00 pm EST

  • Location:

    Miami, FL

Stephanie Willis will speak on the panel, "Fraud and Compliance Issues for ACOs and Integrated Health Systems," at the 14th Annual Conference on Emerging Issues in Healthcare Law presented by the American Bar Association in Miami, FL.

Given that health care reform has inspired a rising tide of institutional, individual, and group-based health care providers entering into complex collaborative relationships, fraud and abuse concerns have become more important to analyze in the context of integrated delivery arrangements, clinically-integrated networks, and ACOs.

Topics to be covered include:

  • The requirements to qualify as an ACO under the MSSP and how they are distinguished from other integrated delivery arrangements.
  • The fraud and abuse provisions relevant to ACOs and other integrated delivery arrangements including physician self-referrals, kickbacks, beneficiary inducements, and gain-sharing arrangements.
  • Relevant government guidance including MSSP OIG Waivers (Interim Final Rule), Compliance
    Program Guidances.
  • Hypotheticals and potential ways to structure ACOs and other integrated delivery arrangements to comply with legal requirements including implementing a compliance reporting framework throughout the organization; and characteristics of effective compliance with the OIG waivers for ACOs preparing to apply for, or participating in, the Medicare Shared Savings Program.


  • Thomas D. Anthony - Chair, Health Care Industry Practice, Frost Brown Todd, LLC, Cincinnati, OH (Moderator)
  • Vicki L. Robinson - Senior Counselor for Policy, Office of the Inspector General, Department of Health and Human Services, Washington, DC
  • Stephanie D. Willis - Associate, Mintz Levin, Washington, DC

Event Details