This is the fourth in a five-part series discussing the new Value-Based Regulations adopted last year by the Centers for Medicare & Medicaid Services and the Office of Inspector General.

The Stark Meaningful Downside Financial Risk Arrangement exception is designed to accommodate alternative payment models that provide for potential financial gain in exchange for undertaking some level of downside financial risk. CMS believes that financial risk, when tied to the achievement, or failure to achieve, value-based purposes, will incentivize the type of behavior-shaping necessary to transform our health care delivery system into one that improves outcomes and controls the costs of the healthcare services.