Greg Anderson

Greg is a partner in the healthcare practice group of HORNE LLP and concentrates his practice in consulting on income distribution plans for physician group practices; design, implementation and fair market value studies related to hospital/physician employment and other compensation arrangements; and the valuation of medical practices, hospitals, diagnostic facilities, ambulatory surgery centers and other health care facilities.
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Recent Posts

May 16, 2019

BPCI Advanced – To Apply, or Not to Apply?

With mandatory programs on the horizon, the voluntary Bundled Payments for Care Improvement Advanced (BPCI-A) program offers early access to data and valuable experience in redesigning patient care. But with applications closing June 24, 2019, healthcare organizations will need to make some quick decisions about participating in this voluntary Medicare bundled payment program.

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Topics: BPCI-A

January 23, 2019

Forks in the Road to BPCI-A Participation

“We want to pay for outcomes, not process ... We need results, American patients need change, and when we need mandatory models to deliver it, mandatory models are going to see a comeback.”

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Topics: BPCI-A

July 24, 2018

BPCI Advanced Model – Deadline Fast Approaching

The final phase of CMS’ voluntary Bundled Payments for Care Improvement Advanced (BPCI-A) application process is finally here. Whether your hospital or physician practice intends to participate in the model beginning October 1 (or in a future year) or you are a healthcare attorney advising an organization that intends to participate, CMS’ recent announcements regarding the model are noteworthy.

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Topics: Bundled Care, BPCI-A

July 19, 2018

Getting it Right: Traits of Effective Physician Compensation Models

As value-based payment models gain traction, healthcare organizations are feeling pressure to control costs and improve the quality of patient care, all at a time when the supply of physicians is falling short of demand.

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Topics: Physician Compensation, Value-Based Care

July 12, 2018

How Will You Win the War for Physician Talent?

Competition for physicians is already heated. It’s about to get scorching. Demand is on a trajectory to drastically outpace supply, with a projected shortage of up to 120,000 physicians by 2030, according to the Association of American Medical Colleges.

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Topics: Physician Compensation

March 29, 2018

MedPAC to Congress: Replace MIPS With Voluntary Value Program

Congress should repeal MIPS and replace it with a new Voluntary Value Program (VVP), according to a report released recently by the Medicare Payment Advisory Commission (MedPAC), the independent advisory agency tasked with making recommendations on Medicare policy.

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Topics: Payment Models, MIPS Healthcare, MedPAC

March 26, 2018

Bipartisan Budget Act Taps the Brakes on MIPS—But Don’t Slow Down!

The Bipartisan Budget Act of 2018 (BBA18), signed by President Trump on February 9, includes several provisions that will affect healthcare providers’ Medicare reimbursement—in both positive and negative ways.

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Topics: Payment Models, MACRA

January 04, 2018

MedPAC and OIG Weigh in on MACRA

The month of December saw additional and important communications from two watchdog groups on the subject of the Medicare and CHIP Reinvestment Act (MACRA) of 2015.

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Topics: MedPAC, MACRA

July 13, 2017

What’s the Value of Innovation? (Part 2)

The previous installment of this blog series described the CMS Innovation Center and its mission to test innovative payment and delivery models and to implement the MACRA Quality Payment Program (QPP).

The QPP is designed to help achieve HHS’ goal of tying half of Medicare fee-for-service payments to quality or value through Advanced Payment Models (APMs) by 2018. Advanced APMs, one of the two tracks of MACRA, allows physician practices to earn more by assuming some financial risk related to patients’ outcomes. Certain Accountable Care Organizations (ACOs) in the Medicare Shared Savings Program (MSSP), including the new MSSP Track 1+ ACO, qualify as Advanced APMs.

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Topics: Value-Based Care, APMs, Quality Payment Program, MACRA Summary

June 22, 2017

What’s the Value of Innovation? (Part 1 in a 2-part series)

The Affordable Care Act created the CMS Innovation Center to allow Medicare and Medicaid programs to test innovative payment and delivery models that improve patient care and lower healthcare costs.

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Topics: Affordable Care Act Summary, APMs

March 30, 2017

How Do Recent Settlements Give Insight into Effective FMV and CR Compliance Programs?

As discussed frequently in compliance and health care conferences and forums and on this page, fair market value (FMV) of payments to referring physicians is an essential compliance requirement of the Stark law and federal anti-kickback statute. Physician compensation in excess of FMV is at the crux of much health care enforcement activity. As noted by Richard Kusserow, former Inspector General, “Arrangements with physicians are the highest compliance risk area in 2017” (“Kickback Cases Remain Top DOJ and OIG Priority in 2017,” Strategic Management Services, LLC; Jan. 2017). Mr. Kusserow further explained that whistleblowers are a significant source of enforcement activity.

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Topics: What is Fair Market Value

February 23, 2017

3 Steps to Reduce Fraud and Abuse Compliance Risks in Hospital-Physician Deals

The most astute executives in health systems are rightfully concerned about compliance risks in physician contracting. Among these risks are that a transaction or an arrangement between a hospital and a physician are consistent with fair market value (FMV) and are commercially reasonable (CR) as those terms are defined in the healthcare regulatory context.

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Topics: Physician Compensation, What is Fair Market Value

January 20, 2017

7 Key Steps to Take Now to Get Ahead With MACRA

Like it or not, MACRA is here. MACRA created the new Quality Payment Program (QPP), comprised of two pathways to higher quality: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). MACRA changed the rules, leaving many to face an uncertain future. Amid the uncertainty, however, one thing is sure: passivity will be costly. Indecision will not prevent or delay physician’s placement into the quality and efficiency compensation measurements of MIPS.

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Topics: MACRA Summary