The Partnership to Empower Physician-Led Care (PEPC) is pleased to submit our comments on HHS OIG Anti-Kickback Statute. PEPC is a coalition of stakeholders supporting independent physicians and practices in the movement to value-based care.
- PEPC urges OIG not to apply the proposed 15-percent requirement to independent physicians.
- PEPC believes that the proposed cyber security technology safe harbor should not be used to support intentional or unintentional anti-competitive behavior. While we support OIG’s decision, this could be a disincentive for independent practices and physicians given the potential magnitude and cost of administrative burden associated.
- PEPC supports the addition of specific language preventing donors from engaging in information blocking.