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Vertical Integration in Healthcare Transactions: Mitigating Risks and Creating Firewalls

Fraud and Abuse, Corporate Practice of Medicine, Conflicts of Interest, Antitrust, Data Sharing

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

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Wednesday, April 28, 2021

Recorded event now available

or call 1-800-926-7926

This CLE course will guide counsel on vertical integration in the healthcare industry. The panel will review the legal risks of vertical integration that arise from fraud and abuse to corporate practice of medicine and conflicts of interest. The panel will discuss the key considerations when creating firewall structures and offer best practices for vertical integration.


In the healthcare industry, vertical integration occurs when, for example, a hospital acquires physician practices, or health plans acquire a pharmacy benefit manager, creating an expansion up or down the service chain beyond the organization's current offerings. The healthcare industry has seen an increase in vertical integration. However, when organizations integrate vertically to increase their service offerings, they face additional risks, including antitrust, fraud and abuse, corporate practice of medicine, and conflicts of interest.

Healthcare counsel and organizations must remain vigilant to mitigate these risks. For example, to reduce the risk of Stark violations, they must ensure that referrals for certain services are part of an enumerated exception and not the basis for physician compensation. If a physician has ownership in a vertically integrated service, that ownership must be carefully structured to comply with the Stark Law.

If there are actual or perceived conflicts of interest, firewalls must be put in place to reduce the risks associated with these conflicts of interest. Firewalls will also mitigate data sharing risks among the groups in the vertically integrated organization.

Listen as our authoritative panel of healthcare attorneys examines vertical integration and the potential legal risks that arise from fraud and abuse to corporate practice of medicine. The panel will discuss the key considerations when creating firewall structures and offer best practices for vertical integration.



  1. Vertical integration: considerations
  2. Legal risks
    1. Fraud and abuse
    2. Corporate practice of medicine
    3. Data sharing
    4. Antitrust
    5. Conflicts of interest
  3. Creating firewalls
  4. Best practices for vertical integration


The panel will review these and other key issues:

  • What are the essential considerations for healthcare organizations considering vertical integration?
  • What legal risks will healthcare organizations face when increasing service offerings through vertical integration?
  • What steps should healthcare counsel take to mitigate the risks associated with vertical integration?


Gilman, Alexis
Alexis J. Gilman

Crowell & Moring

Mr. Gilman advises and represents clients on a broad range of civil antitrust and competition matters, including merger...  |  Read More

Slavkin, Robert
Robert E. Slavkin

Chair, Healthcare Practice Group

Mr. Slavkin is the Chair of the Healthcare Practice Group, a multidisciplinary team recognized nationally for...  |  Read More

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