Gosfield and Shay on Health Law

Episode Summary:In this episode, Alice Gosfield breaks down co-management agreements and clinical integration for healthcare organizations. She explains what works, what doesn’t, and the essential strategies physicians and hospitals need to create high-performing, legally compliant collaboration models. From aligning financial incentives to building a shared culture, Alice shares actionable insights for anyone developing integrated healthcare programs.
 
What You Will Learn in This Episode:
The definition of co-management agreements and their role in healthcare collaboration
Key steps to create compliant co-management agreements
Legal and operational elements necessary for effective clinical integration
Alice’s four Fs framework: form, function, finance, and feeling
The importance of physician-to-physician collaboration
Tools like the Clinical Integration Self-Assessment for evaluating group readiness
How standardized protocols, performance metrics, and care pathways reduce fraud and abuse risks
The role of bundled payments in supporting integrated care models
Key Timestamps:
00:00 – Introduction to co-management agreements02:15 – Creating compliant co-management agreements04:30 – Understanding clinical integration and its legal origins05:00 – Alice’s four Fs framework for evaluating integration06:20 – Physician collaboration and leadership in integrated models08:15 – Clinical Integration Self-Assessment tool explained10:00 – Reducing fraud and abuse risks through standardization12:05 – The role of bundled payments in clinical integration14:00 – Closing thoughts and next steps for healthcare organizations
About the Show:
Gosfield & Shay on Health Law is a podcast dedicated to unpacking the complexities of health care compliance, physician group structuring, and federal regulatory policy. Hosted by Alice Gosfield, one of the nation’s leading health care attorneys, the show helps physicians, practice managers, and hospitals navigate the legal landscape with clarity, strategy, and confidence.

Episode Summary:In this debut episode of Gosfield & Shay on Health Law, nationally recognized health care attorney Alice Gosfield clarifies one of the most confusing areas in physician compliance: Stark Law. Drawing on decades of experience advising physicians, hospitals, and group practices, Alice debunks persistent myths around fair market value, commercial reasonableness, designated health services, and group practice definitions. She explains why billing under a single tax ID doesn’t automatically mean Stark compliance, how incident-to-billing and anti-markup rules really work, and what pitfalls physician groups often overlook. Listeners will come away with sharper insights and practical clarity on how to structure arrangements without triggering Stark violations.
Key Timestamps:
00:01 – Show introduction and welcome02:00 – Alice Gosfield’s background and path into health law05:10 – What the Stark statute regulates and which providers it applies to08:30 – The difference between fair market value and commercial reasonableness12:05 – What counts as designated health services under Stark15:20 – Why billing under a single tax ID does not guarantee Stark compliance18:45 – Independent contractors and how they may be paid22:10 – Can hospitals pay physicians for quality performance?25:30 – How group practice requirements are structured and common compliance mistakes29:15 – Understanding “incident-to” billing and the anti-markup rule34:05 – Compensation models, productivity bonuses, and profit-sharing under Stark38:30 – Final takeaways and closing thoughts
About the Show:
Gosfield & Shay on Health Law is a podcast dedicated to unpacking the complexities of health care compliance, physician group structuring, and federal regulatory policy. Hosted by Alice Gosfield, one of the nation’s leading health care attorneys, the show helps physicians, practice managers, and hospitals navigate the legal landscape with clarity, strategy, and confidence.