$0 Physician Subsidy – Harnessing the 2021 Stark Law Update into Sustainable, Triple Aim Compensation Design TW

Join us for the American College of Healthcare Executives 2022 Congress on Healthcare Leadership. BKD’s Randy Biernat will be presenting “$0 Physician Subsidy – Harnessing the 2021 Stark Law Update into Sustainable, Triple Aim Compensation Design” on Wednesday, March 30.  

This session will provide a road map for physician employer organizations to adopt a compensation plan methodology to help achieve the “triple aim” as led by the employed medical staff. This approach moves beyond “margin for mission” philosophy of provider integration heavily relied upon for 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-zero 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 from a facility and payor standpoint. Presenters will introduce the key concepts, present an adoptable compensation framework, describe how to get started, and share how to monitor and manage compliance risks associated with this new type of compensation plan.


Randy Biernat, BKD 
Eric Leafgreen, Banner Health   

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 help achieve triple aim-type alignment 

Click here to learn more about this event. Questions? Contact Jenalee Davidson at jdavidson@bkd.com

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