Corporate Compliance

Organized healthcare arrangements

Compliance Monitor, April 8, 2005

Q. What is an organized healthcare arrangement (OHCA)?

A. An OHCA is an arrangement of covered providers that includes the following integrated care delivery and payment options:

  • A clinically integrated care setting in which individuals typically receive healthcare from more than one provider
  • An organized system of healthcare in which more than one CE participates and in which the participants present themselves to the public as part of a joint arrangement

In a system where more than one CE participates, the CEs must work together on at least one of the following:

  • Utilization review
  • Quality assessment and improvement activities
  • Payment activities, if the OHCA participants share the financial risk for delivering healthcare

To qualify as an OHCA, healthcare providers must present themselves as a clinically integrated joint arrangement and must have joint utilization review or quality assurance and share financial risk.

Editor's note: Attorney Bill Roach of McDermott Will & Emery in Chicago answered this question. This is not legal advice. Consult your attorney for legal matters.

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