Social Supports in the Provider Setting: Anti-Kickback and Beneficiary Inducement Safe Harbors
This Briefing is brought to you by AHLA’s Fraud and Abuse Practice Group.
- March 06, 2024
- Rachel Landauer , Center for Health Law and Policy Innovation, Harvard Law School
- Meryl Katz , Kaiser Foundation Health Plan, Inc.
Health care organizations are increasingly engaging with individual-level social needs that impact health (health-related social needs or HRSN). The momentum is buoyed by U.S. Department of Health and Human Services’ use of rulemaking and other authorities to advance regulatory mandates, incentives, and flexibilities that promote the integration of HRSN services and supports into health care delivery and financing. By way of some recent examples, in 2022, the Centers for Medicare and Medicaid Services (CMS) finalized rules introducing social determinants of health screening into the Inpatient Prospective Payment System and Special Needs Plan Health Risk Assessments. In 2023, CMS issued a long-awaited informational bulletin detailing coverage pathways for HRSN services and supports in Medicaid and CHIP. And as of the start of this year, new codes make health-related social needs risk assessments, as well as community health worker services and patient navigation services (both of which help patients connect to resources that address unmet HRSN) reimbursable under Medicare Part B.
ARTICLE TAGS
You must be logged in to access this content.