Structuring and Managing Clinically Integrated Networks – The View From 2019: What’s New and What Do We Do Now?

New Legal and Regulatory Issues for CINs, Organizational Structure, Governance, and More

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, February 27, 2019

Recorded event now available

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Program Materials

This CLE webinar will focus on hospital-physician “clinically integrated network” (CIN) organizations in the context of the evolving legal and regulatory environment, including the 2018 introduction of “Pathways to Success,” the “Regulatory Sprint to Coordinated Care” and court activity that affects interpretations of, and the future of, the Affordable Care Act. The panel will consider the potential effect of pending and evolving legal and regulatory changes to CINs. The panel will discuss Medicare payment rules (including PIP restrictions), Medicare fraud and abuse laws, antitrust laws, state and federal restrictions for tax-exempt entities, and a variety of other state and Federal laws and regulations as they pertain to hospital and physician contributions and distributions to CINs.


The Affordable Care Act and its progeny increased attention on quality, cost and value in healthcare delivery in the United States. New emphasis on value has been moving payers, hospitals and health systems to work with physicians to manage costs and improve quality and efficiency. With the proliferation of bundled payments and other value-based payer models, these collaborations have become more important—and complex.

The complexity has been increased by an evolving and uncertain regulatory environment that includes many recent developments that may affect whether and how hospitals and physicians parties may share risk and rewards in CINs, including the 2018 initiation of “Pathways to Success” for ACOs, the “Regulatory Sprint to Coordinated Care” and its potential implications for the application of Medicare Fraud and Abuse Laws to hospital-physician relationships that enhance care coordination, and the outcome of Federal litigation challenging the existence and application of the Affordable Care Act.

Listen as our authoritative panel of healthcare legal advisers provides a thorough review of CINs, how they differ from other physician-alignment methods, factors to consider when forming or participating in a CIN- especially in light of ongoing and expected regulatory changes, organizational structure and governance issues, and regulatory compliance challenges, particularly as they relate to payments to physicians and other CIN participants.



  1. The realities of CINs and other alignment and payment methods in a changing environment
  2. Factors to consider when selecting the physician-alignment method platform
  3. CIN organization and governance and current challenges related to an evolving regulatory environment
  4. Regulatory challenges and opportunities, from PIP restrictions to the potential effect of the “Regulatory Sprint to Coordinated Care”
  5. Best practices for structuring CINs, as well as in advising them through their lifecycle
  6. Participant payment issues, including fair market value


The panel will review these and other key issues:

  • The place of CINs among various alternative alignment and payment models
  • Regulatory challenges CINs face under federal and state law, including the physician self-referral and antikickback laws and regulations, and laws and regulations related to tax exemption
  • Factors healthcare providers and their counsel should consider when selecting and then managing a physician-alignment program
  • When and why contributions to and payments from a CIN should be fair market value, and factors to consider when making a determination of fair market value
  • Special considerations when CIN participants are hospital-employed physicians


Ferrari, Andrea
Andrea M. Ferrari, JD, MPH

HealthCare Appraisers

Ms. Ferrari focuses on physician payments related to hospital-physician alignment and efficiency improvement...  |  Read More

Watson, Mark
Mark C. Watson

Hancock Daniel

Mr. Watson focuses on the representation of various providers, including hospitals, health systems, physician groups,...  |  Read More

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