What is clinical integration?
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Clinical integration is a medical practice model that brings together hospitals with providers from different practices and specialties to coordinate care. As a result patient care is safer, more effective, and more efficient. When providers work together to care for patients in a clinically integrated environment they can deliver higher quality care more efficiently and with greater value to patients to a degree un-attainable if those same providers continued to work independently within their practices.
Clinical integration is an economic model whereby integrated providers share the costs of their efforts making care more affordable for all. It is a legal model through which members of a clinically integrated entity present themselves to the market place as a single entity, not as individual practices. As a single entity the integrated practices can participate in joint venture activity such as payer contracting if it is ancillary to and supportive of their efforts to deliver greater value to consumers.
Why would we want to be clinically integrated?
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For all of the reason above, clinical integration allows medical communities the opportunity to coordinate care, improve the value of medical services, promote that improved value, attract greater market share, and conduct joint venture activities as a single entity for various projects such as payer contracting. Maintaining clinical integration provides continuous improvement in every aspect of your practice and provider organization.
What are the benefits of clinical integration?
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Patients can expect more highly coordinated care, a safer, more effective, more efficient healthcare en-vironment, and greater healthcare value. Providers can deliver that value, leveraging higher value services in the market place, enhancing their revenue, and participating appropriately in joint venture activities as a single entity.
How do we, as a medical organization, avoid FTC and/or DOJ investigation?
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Do the right thing. These agencies want to preserve competition in the market to drive up quality of care and drive down price. Anti-competitive behavior, such as competing providers getting together for no other reason than to contract with payers, will not be tolerated. This is viewed as colluding on price and can be illegal. However, FTC and DOJ will allow anti-competitive behavior under certain circumstances. One such circumstance is this: if the corroborative activity by the practices is ancillary to the delivery of value to consumers, this outweighs the potential harm done through the anticompetitive behavior.
Thus, your organization must focus on improvements in clinical quality and efficiency, insuring provider participation, and the investment of human and financial capital. In addition, the organization must be able to generate data that supports the claim of greater value as a clinically integrated entity. If these are in place, and your organization negotiates joint venture payer contracts, this activity will be seen as ancillary to and supportive of your clinical integration. It is highly unlikely your organization will be in-vestigated for collusion under the rule of reason.
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