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Legal Statement

The Centers for Medicare and Medicaid Services (“CMS”) and the U.S. Department of Health and Human Services’ Office of Inspector General (“OIG”) have made available certain waivers of specific fraud and abuse laws (the “ACO Participation Waivers”) in connection with the operation of an Accountable Care Organization (“ACO”) participating in the Medicare Shared Savings Program (“MSSP”).  In order to receive the benefit of an ACO Participation Waiver, the BJC HealthCare ACO (“BJC-ACO”) is required to publicly disclose arrangements for which waiver protection has been sought.  Presently, waiver protection has been sought for the following arrangements:

  1. Waiver protection has been sought for a compensation model developed for use with hospitalist physicians employed by Physician Groups, L.C. d/b/a BJC Medical Group of Missouri and Fairview Heights Medical Group, S.C. d/b/a BJC Medical Group of Illinois (collectively, “BJCMG”) related to services provided by BJCMG-employed hospitalists at those BJC hospitals participating in the BJC-ACO at which the hospitalists practice. The effective date of the compensation model is July 1, 2018.  The purpose of this model is to better align hospitalist physician incentives with hospital, BJC-ACO and MSSP goals.
  2. Waiver protection has been sought for certain written contractual arrangements by and among BJC HealthCare and BJC-ACO-participating physician practices, beginning January 1, 2014, under which BJC has made donations of certain electronic health record (EHR) technology used to facilitate the exchange of electronic health data between and among providers.   The purpose of the arrangements described above is to continue and enhance the ability of BJC-ACO-participating healthcare providers to receive and exchange health data in the interest of: (1) reducing medical errors, improving care decision-making and reducing costs; and (2) providing a more efficient and effective means of collecting and reporting quality, cost and performance information, as required by the MSSP or as needed to further the ACO’s efforts to succeed in the MSSP.

See also: BJC HealthCare policy regarding Vendor Information and Patient Privacy.