Structuring and Managing Clinically Integrated Networks The View From 2020: What's New and What Do We Do Now?

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

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

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Conducted on Tuesday, August 18, 2020

Recorded event now available

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Course Materials

This CLE course will discuss hospital-physician clinically integrated networks (CIN) organizations in the context of how such developments have affected the 2020 legal, regulatory, and financial environment. Topics will include changes in and a new perspective on 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. A 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 critical--and complicated.

An evolving and uncertain market and regulatory environment heighten the complexity. Several recent developments may affect whether and how hospitals and physicians share risk and rewards in CINs, including new proposed regulations from the "Regulatory Sprint to Coordinated Care" and the significant and complex effects of the COVID-19 public health emergency and related market and regulatory changes.

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



  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 impact 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 anti-kickback laws and regulations, and those related to tax exemption
  • Factors healthcare providers and their counsel should consider when selecting and/or managing a physician-alignment program in 2020
  • When and why contributions to and payments from a CIN should be fair market value, and factors to consider when deciding 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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