liThe general idea is to get providers across the continuum of care to band together, work on reducing costs and improving quality, continue to be paid on a fee-for-service basis by CMS, and then retrospectively look at system-wide savings (e.g., avoided readmissions) and share those savings around. Sharing those savings around outside of an integrated delivery system raises a host of potential antitrust, fraud and abuse (anti-kickback), Stark and CMP issues, and the statute authorizes the development of waiver programs and safe harbors in order to make it all work. It's really a square peg-round hole problem, because the policy basis for making illegal this sort of sharing is grounded on fee-for-service, retrospective reimbursement systems. Prospective payment, particularly bundled payments for episodes of care, eliminates the potential for the harm these rules protect against (over-provision of care due to financial incentives), yet they are still on the books. For example, we want physicians to share in the hospital savings experienced as a result of an avoided readmission which would not be eligible for separate reimbursement; this opportunity will incentivize them to work harder to prevent the readmission. Under current rules, however, a payment by the hospital, directly or indirectly, to the physician, tied to that savings, is impermissible.BOWEL PROGRAM IN SPINAL CORD INJURY: GASTROINTESTINAL TRACT AND NORMAL BOWEL MOVEMENT. ----------------. GASTROINTESTINAL TRACT AND NORMAL BOWEL MOVEMENT.- Joanne tried to palliate the pain she had caused her parents by sending an apology card.
