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Physicians Advocacy Institute

Regulatory Relief/Administration Simplification

PAI promotes policies to enable private practice physicians to organize effectively to deliver high quality, cost-effective care to patient, stressing the need to modernize outdated, restrictive laws and regulations that act as barriers to physicians collaborating in innovative practice arrangements.

PAI Advocacy Initiatives

AKS Comment Letter – On December 31, 2019, PAI provided comments in response to new safe harbors and modifications to existing safe harbors under the Anti-Kickback Statute to better account for the shift towards participation in value-based arrangements. New safe harbors proposed include those for: Care Coordination Arrangements (CCAs), VBAs with Substantial for Full Downside Risk; Patient Engagement and Support Arrangements; Donation of Certain Cybersecurity Technology and Related Services; Outcomes-Based Payment Arrangements; and CMMI Model Participants.

Stark Law Comment Letter – On December 31, 2019, PAI provided comments in response to new exceptions and technical changes to the Physician Self-Referral (Stark) Law. The policies PAI weighed in on include new exceptions for: Full-Risk Models, Value-Based Arrangements (VBAs) with Meaningful Downside Financial Risk to the Physician; and General VBAs.

PAI Comments on CMS' RFI on Reducing Administrative Burden (PDF)
PAI submitted comments in response to CMS’s Request for Information (RFI) on Reducing Administrative Burden to Put Patients Over Paperwork. In its comments, PAI supported CMS efforts to reduce administrative burden and encouraged it to adopt policies that help optimize time spent in physician-patient encounters, including those on prior authorization, Network Adequacy, Recovery Audit Contractors (RACs), Streamlining/Aligning federal and state requirements, etc.

PAI’s “Red-Tape Relief” Recommendations to Congress
PAI submitted twenty-five specific policy recommendations to the U.S. House Ways and Means Committee on Health to reduce unnecessary and duplicative Medicare-related regulatory burdens on physicians’ practices. 

Letter to HHS to Modernize “Anti-kickback” Law
PAI’s letter urges HHS to address outdated anti-kickback restrictions that unfairly disadvantage physicians’ ability to establish physician-led initiatives to value-based care.

Letter to CMS to Modify Physician “Self-Referral” Restrictions
PAI’s letter addresses the need to modernize the “Stark” self-referral law to enhance opportunities to improve the health care system by fostering innovative approaches to physician collaboration while taking into consideration the law’s original goal to deter health care decisions that are motivated by financial self-interests.