Dorothy is 81. She is on 11 medications and manages three specialists. Her primary care practice knows her well.

It is Saturday night, and she develops shortness of breath. She calls an ambulance and ends up in the emergency room. Nobody at the ER has her medication list. Nobody calls her primary care practice. No one knows what her care team has done to stabilize her, what her baseline looks like, or what her support system is at home. She is admitted to the hospital and discharged a few days later to a skilled nursing facility. Eventually she is discharged home, is confused about a scrambled medication regimen, and ends up right back in the hospital. She no-shows for a routine follow-up, which is the first time the practice is alerted something might be wrong.

Walk back through that and count the places where somebody who knew Dorothy could have changed what happened.

Saturday evening, before the ambulance, is the first one. Shortness of breath in an 81-year-old on 11 medications is sometimes an emergency and sometimes a diuretic adjustment and sometimes something else. Knowing her baseline would be helpful. The people who knew her baseline were not reachable, because nothing in the fee schedule pays a practice to be reachable at nine o'clock on a Saturday night unless a practice is part of an accountable care organization that has built out the infrastructure to support that.

The emergency department is the second. The physician there is paid to evaluate her and make a disposition decision. Nobody is paid to call her practice before that decision gets made, the information isn’t available in the ER EHR, so it gets made without the information that could have improved it.

Then the hospital stay, where the team is accountable for stabilizing her and not for what happens to her afterward. Then the transfer to skilled nursing, where hospitals are required to do discharge planning but nothing pays for the quality of the match or the depth of the handoff. Then the discharge home, where her medication regimen came apart.

At none of those points was there a person whose job was ensuring Dorothy herself received the care (often the non-billable kind) that would ensure a successful return home. Everyone involved did the job they were paid to do. The gaps, or the non-billable activities and coordination, belonged to nobody in particular.

Medicare does pay for pieces of this after the fact. Transitional care management codes exist for exactly this situation, but the clock starts at discharge and it is short: interactive contact within two business days, and a face-to-face visit within seven or fourteen calendar days depending on the complexity of the decision-making. Miss the window and the work stops being billable. Being able to bill means first knowing the patient is returning home.

There is also a federal rule, which most clinicians don't know about. Since April 2021, hospitals have had to send an electronic notification when a patient registers in the emergency department, is admitted, or is discharged or transferred. The obligation falls entirely on the hospital. Nothing requires a practice to be able to receive the notification, nothing in the fee schedule pays a practice to get connected, and hospitals are not required to deliver anything into a physician's inbox. Even where it works, volume can defeat the purpose: Atrius Health in Massachusetts found that a single admission could generate six or more separate messages, and moved them out of physician inboxes into a dashboard. To make matters worse, the rule covers hospitals and not skilled nursing facilities.

Meanwhile, everything that happened as a result of this breakdown? It has a billing code:

As you can see, the incentive issues aren’t limited to the physician fee schedule, but are baked into inpatient sites of care as well. Once a patient is admitted, a hospital's financial and operational focus is optimized for the four walls of that acute stay. There are readmission penalties, capped at three percent and applied only to base operating DRG payments across six conditions and procedures, and there are modest quality adjustments. I liken these to trying to retrofit a solution to the structure that didn’t anticipate what the incentives would do. Beyond that, other than in episodes of care models like BPCI-A, TEAM, CJR, etc., hospitals have no structural incentive to orchestrate a safe journey past the point of discharge. The moment the bed empties, the revenue stops, and the patient's trajectory along the care continuum becomes someone else's blind spot. I have heard more than one primary care physician call it a “black hole” when they lose their patients to the acute through post-acute continuum of care. I have heard countless PCPs tell me over the years they NEVER hear from hospitals or post-acute facilities.

Dorothy's daughter believed her mother was moving through a system that was keeping track of her, that was acting in ways that would best ensure the most positive outcome possible.

The machine is functioning exactly as it was engineered to function. But do any of us really understand what we built when we structured our healthcare system?

Charlie Munger famously said, "Show me the incentive and I'll show you the outcome." It’s heard so often it almost feels meaningless.

I see it as a statement about what I like to call “healthcare physics.”

Water flows downhill because of a slope. It is entirely predictable. You cannot get mad at gravity, and you cannot lecture the water into flowing uphill. There is no single villain to blame. Why? Because the outcome is baked into the architecture. When an incentive is created, you have to ask: Where does the value actually land?

To understand this, look at something else we all live with, like we live with the policies that put our healthcare system’s structure in place: the tax code.

Entire professions exist to optimize the tax code, and it sits at the center of many political campaigns. At its core, it is built on a fundamental asymmetry where businesses are taxed on net income, while employees are taxed on gross income. Owners spend first and pay tax on what is left, while employees pay tax first and live on what is left.

The tax code offers structural preferences for ownership, including pass-through deductions, capital gains treatment, and depreciation schedules, none of which have a wage-labor equivalent. While income tax rates at the top brackets have swung wildly over the decades, the structural preference for ownership has survived every administration.

However, an incentive is merely an offer, not a guarantee. The tax code offers you preferential treatment if you choose to bear the risk of ownership, but most people remain W-2 employees because entrepreneurship requires capital and sacrifices safety net benefits like employer-sponsored health coverage. The tax code rewards those who can afford to be wrong or who are brave enough because they want it so badly. It isn't explicitly meant to punish employees, but it creates two different economic realities.

Now apply those exact physics to healthcare.

Start with the rise of Blue Cross in 1929. Then the Stabilization Act of 1942 capped wartime wages but exempted insurance benefits, so employers competing for scarce workers competed with health coverage instead of pay. A 1943 IRS ruling held that employer contributions to group medical coverage weren't taxable income to the worker, and Section 106 of the 1954 Internal Revenue Code wrote that treatment into statute with no ceiling on it. Medicare arrived in 1965. Nobody designed employer-sponsored insurance as the backbone of American healthcare; it grew out of a wartime wage control that happened to have an exception in it.

Through all of it we codified a single rule: we pay for what can be named, coded, and billed, with a heavy preference for procedures.

As clinicians and others working in healthcare in some capacity, we rarely stop to think about how the system works, why it works that way, or how it might work differently. We inherit a set of operational habits and financial realities often without ever questioning how policies constructed a century ago became immutable dogma. We treat century-old compromises as "just the way things are."

What is billable? Scans, hospital admissions, surgical procedures, and specialty consults. What is unbillable, or historically undervalued? To name just a few:

Medicare has been adding codes for this work for over a decade. Transitional care management in 2013. Chronic care management in 2015. In 2024, Community Health Integration (G0019, G0022) for the upstream barriers that keep a practitioner from diagnosing or treating a problem, and Principal Illness Navigation (G0023, G0024, with separate codes for peer support) for patients with a serious high-risk condition such as cancer, heart failure, COPD, dementia, HIV/AIDS, severe mental illness, or substance use disorder. Advanced Primary Care Management in 2025, a monthly per-patient bundle whose required elements include risk-stratifying your panel and making follow-up contact within seven calendar days after an emergency department visit or a discharge from a hospital or a skilled nursing facility.

All of these came from CMS through annual fee schedule rulemaking rather than from the Affordable Care Act, which is where most people assume they came from. But incentives created by the ACA, like the ACO, mean physicians and others need to be paid for work they weren’t paid to do before if they want to be successful. But look at what a practice has to build before it can bill any of it.

CHI and PIN both require a separate initiating visit performed by the same practitioner who will bill the service, and it can't be a low-level visit or an ED or inpatient encounter. Both require documented advance consent, and PIN requires consent again every year. The auxiliary personnel doing the work, usually community health workers or clinician navigators, have to meet state certification requirements, or in states with none, be trained in seven specified competencies. Their time has to be documented in the medical record and verified by the billing practitioner. Most of these services are built in 60-minute monthly increments of staff time, which means the practice needs a way to capture minutes it has never captured before.

So the work is payable now, but only by a practice that has already built a care management team, a consent workflow, a time-tracking system, and some way of finding out that something happened to a patient. Practices that have those things generally have them because they joined an accountable care organization, where the claims feeds, the care management staff, the data and real-time patient notification technology, and the financial reason to care about total cost of care all already exist.

Joining an ACO is really a decision to change what the medical practice is, how it is governed, what it reports, how it is staffed, and whether it can absorb a year in which spending lands over benchmark, should that be the result. It takes capital, time, and a tolerance for risk that a practice may not have. It is the same kind of offer the tax code makes. The door is open, and walking through it costs you the thing you were counting on.

Sadly, the system is not set up so that the physics of healthcare work for the patient.

Patients assume that someone, somewhere, is accountable for their well-being. They put their trust in healthcare professionals that they operate in the ways that will be best for the patient. They do not realize, as many healthcare professionals themselves also don’t realize, that no one is accountable for the results of failing to prevent disease, failing to detect it early, failing to engage patients proactively, failing to offer quick access to urgent needs, failure to ensure an optimal and safe patient journey, and failing to avoid unnecessary hospital admissions.

The denominator is a named population that somebody owns over a period of time. Fee-for-service has only a numerator, which is the count of services delivered today. In the U.S. machine, no one owns the population, but everyone owns a transaction.

It is largely patients and W-2 wage earners that fund the system through taxes and premiums, yet they have no door to walk through that lets them collect on procedural inflation.

Because no one owns the population and everyone lives off the transactions, the system attempts to police itself through an elaborate apparatus of quality metrics. But this creates a secondary trap. Driven by reporting requirements and payment incentives, health systems have become exceptionally good at optimizing for the test.

This is Goodhart’s Law in action. When a clinical metric becomes a target, it ceases to be a reliable measure of health. Instead of tracking actual outcomes, the industry relies on process proxies like documentation checkboxes and administrative compliance targets. Then it mistakes them for clinical excellence. A health system can score near-perfect marks on a quality measure simply because an electronic health record prompts a staff member to log a completed step, while the patient's actual day-to-day health trajectory remains unchanged.

In 2022, researchers at Weill Cornell compared the MIPS scores of 80,246 primary care physicians against process and outcome measures built from Medicare claims covering 3.4 million patients. The scores turned out to be inconsistently related to both. Nineteen percent of the physicians with the lowest MIPS scores landed in the top quintile on patient outcomes, and 21 percent of those with the highest scores landed in the bottom quintile. Two of the process measures were so thoroughly topped out that the median physician scored 100 percent, which is what a measure looks like once the software has been configured to satisfy it. And the physicians who scored poorly on MIPS while producing superior outcomes were disproportionately the ones caring for the most medically complex and socially vulnerable patients.

That paperwork carries a cost. An earlier study by the same group found that practices spent an average of $12,811 per physician on MIPS participation in 2019, and that clinicians and staff together spent roughly 202 hours per physician on it. The physicians' own share came to more than 53 hours, which the authors noted is enough clinic time to see about 200 additional patients.

Ultimately, our performance data measures our compliance machinery, not our population's health. By rewarding systems for proving they followed a protocol, we focus on those outcomes instead of patient health outcomes.

The tax code ran into this problem a long time ago and built a defense against it. Under the economic substance doctrine, codified at Section 7701(o) of the Internal Revenue Code, a transaction is respected only if it changes the taxpayer's economic position in a meaningful way apart from its tax effects, and only if the taxpayer had a substantial purpose beyond those effects. Satisfying every technical requirement is explicitly not enough. A structure can be flawless on paper and still be disregarded, because nothing real happened.

Healthcare quality measurement has no equivalent doctrine. A practice can satisfy every element of a measure while nothing about the patient's position has meaningfully changed, and no provision anywhere says that fails to count. The measure was met. That ends the inquiry.

The economic substance doctrine was codified by Section 1409 of the Health Care and Education Reconciliation Act of 2010, the reconciliation bill Congress passed to amend the Affordable Care Act, a few sections after provisions amending the ACA directly. In one part of that law we told taxpayers that form without substance would not be respected. In another we built a quality apparatus that respects almost nothing else.

CMS is beginning to recognize the breaking point. On July 14, 2026 it released the 2027 Physician Fee Schedule proposed rule. Some notable inclusions:

Paying more when a relationship exists. G2211 is currently a flat add-on code for E&M visits that are part of an ongoing longitudinal relationship. CMS proposes converting it into a percentage-based modifier worth 16 percent on top of the associated office visit, and a second modifier worth 32 percent that would be available only to clinicians participating in any Track of the Medicare Shared Savings Program (MSSP) ACO or CMMI’s Long-Term Enhanced ACO Design (LEAD) Model. The same visit, with the same patient and the same clinical content, would carry twice the premium depending on whether the practice has taken on total cost of care accountability. This is the same move the tax code makes when it taxes an identical dollar at one rate as wages and another as a qualified distribution. The work does not change. The structure around the work does.

Making accountable care worth more to join and continue participation in, even when downside risk increases. CMS proposes raising the shared savings rate in BASIC track Level E from 50 to 60 percent, increasing the prior savings adjustment scaling factor from 50 to 75 percent, risk-adjusting the cap on upward benchmark adjustments, and adding a growth adjustment that rewards ACOs for recruiting clinicians who are new to value-based care. It also proposes letting eligible ACOs apply to reduce or eliminate Part B cost-sharing for their assigned beneficiaries.

Rebuilding practice expense from the ground up. CMS proposes retiring the Indirect Practice Cost Index, the step that still anchors practice expense values to physician survey data collected in 2007, over a two-year transition. It would also change how indirect costs are allocated across services and add a stabilizer capping annual swings in practice expense RVUs at plus or minus five percent. CMS frames this as a technical methodology update, and it is one, but it will redistribute money across specialties for years.

Questioning the foundation. CMS is asking whether the CPT and RUC process should remain the basis of physician payment at all. They ask whether current coding reflects medical necessity and modern practice, whether AMA licensing of CPT creates barriers to innovation, and whether payment could eventually run on ICD-10-PCS procedure codes instead. It is separately asking whether Medicare should build a prospective "primary care global period" that bundles office visits, annual wellness visits, and care management into a single payment, and whether the existing care management codes should be consolidated.

To be clear, Requests for Information are not proposals. But they may signal what to expect in the next round, and seek feedback from those who do write a comment letter during the proposal period ending September 14, 2026. CMS still has to operate within its statutory authority inside the machine Congress built. But it's worth running the physics on the proposals themselves and asking where the value lands. When the value lands on the patient, we have made major progress.

In the tax code, we understand the rules of the game. We know that higher income brackets use marginal rates, and we understand why business owners navigate a different structure.

In healthcare, even those of us working inside the industry often fail to see how the system is engineered. We experience systemic failures, including things like rushed 10-minute visits, clinician burnout, patients showing up only when acute, and fragmented handoffs, as personal failings. We throw around blame, but doesn’t it rest mostly in structural physics?

So the incentives are pointed in a better direction than they were five years ago, and the strongest of them still point at organizations rather than at patients. A practice that wants to be paid for keeping Dorothy out of the hospital can now get paid for it, provided it first becomes the kind of organization that can do that work. Dorothy has no equivalent move available to her. That is the physics as they currently stand.

Until the payment architecture is fundamentally overhauled, we cannot wait for the machine to fix itself. What that asks of clinicians, and of everyone else working inside healthcare, is this:

Stop accepting legacy policies as immutable laws of nature. Nearly everything that feels permanent about how you practice was a decision somebody made, often for a reason that stopped applying decades ago. Understand the economic gravity pulling at your organization, and recognize that when burnout hits, it is frequently a symptom of an incentive structure that trades cognitive depth for procedural volume rather than a failure of your own resilience. If your practice is weighing accountable care, you are actually evaluating whether to become a different kind of organization.

There is a policy window open. The comment period on the CY 2027 proposed rule closes September 14, 2026. Comments are public, they 100% get read, and individuals and organizations can submit them.

Everything above is about who money moves toward. There is a second track running alongside it, which is where patient information is held.

CMS has been building toward this for six years. The 2020 Interoperability and Patient Access rule created the Patient Access API, requiring certain payers to make claims, encounter, and clinical data available to an application of the patient's choosing. The 2024 Interoperability and Prior Authorization rule went considerably further. By January 1, 2027, impacted payers have to run four production interfaces: Patient Access, now including prior authorization decisions and the reasons behind them; Provider Access, which sends a patient's data to the clinicians treating her unless she opts out; Payer-to-Payer, which carries her history when she changes plans if she opts in; and Prior Authorization itself.

Running alongside the regulation is a voluntary effort. In July 2025, CMS asked industry to build a connected digital health ecosystem, and more than 700 organizations pledged to participate. The first wave launched on April 9, 2026 with tools from more than 50 companies, a Medicare App Library of vetted applications for beneficiaries to manage their own records, modern identity verification on Medicare.gov, and an initiative CMS calls Kill the Clipboard, where a patient shares her record at check-in by scanning a code on her phone. CMS is also asking, in the CY 2027 proposed rule, whether participation in a national interoperability network should become a Condition of Participation for hospitals.

So run the same physics on it. Where does the value land?

This one is different, and the reason is Dorothy herself. She was the only party present at every step of her own story. The emergency department did not have her record. The hospitalist did not have her practice's notes. The skilled nursing facility received what the hospital chose to send. Her practice received nothing at all. Across six billable episodes and five handoffs, the single continuous thread was the patient. If she can carry a complete, portable, verifiable record, then the one node that is always present becomes the one node that always has the information, and no payment model has to change for that to be true.

I realize full well that a record is not judgment. A record’s availability doesn’t mean someone will take action on reading, synthesizing, and analyzing it to help drive a superior care journey. On Saturday night, Dorothy did not need her chart. She needed somebody who could read it and tell her whether shortness of breath meant a diuretic adjustment or an ambulance. Handing her the file makes her a better equipped general contractor. It does not relieve her of being the general contractor, which is a job that an 81-year-old on 11 medications should not have to hold.

The physics apply to this track as well. CMS describes the ecosystem work as a movement rather than a mandate, which means the pledges from technology companies are running well ahead of adoption by the practices and hospitals whose workflows would actually have to change.

The tax code worked this out a long time ago. Every January a W-2 arrives, and 1099s, and a 1098 if there is a mortgage, each in a standardized format, each sent both to the taxpayer and to the government. That dual reporting is the reason an ordinary person can argue with the IRS about their own money. You hold the record. You can check it against what they hold. You can take it to somebody who knows what to do with it.

The Patient Access API is the patient's copy. The Provider Access API is the copy that goes to the clinician. In tax, holding your own record was never a solution to anything. It was the precondition for one.

So is this the link that finally gives patients some say over their own trajectory? I think it is necessary and not yet sufficient. For a century, the patient has been the one participant holding nothing the system needed. She brought a body, a premium, and a copay, and the value flowed past her to whoever held the code. A patient who arrives holding her own complete record is, for the first time, holding something the system wants. That is where leverage begins. Whether it becomes real leverage depends on whether anybody is ever paid to act on what she brings.

We cannot get mad at gravity. But once we understand how the slope was built, we can finally stop playing by rules that were never designed to keep us well.

The rule itself, and the news peg. Released July 14, 2026, published July 16, and open for comment through September 14, 2026. Centers for Medicare & Medicaid Services, "Calendar Year (CY) 2027 Medicare Physician Fee Schedule Proposed Rule (CMS-1848-P)," July 14, 2026. cms.gov · The full rule as published at 91 FR 43842: federalregister.gov · The accountable care proposals, including the BASIC Track Level E sharing rate, the prior savings scaling factor, and the Part B cost-sharing waiver: cms.gov

The clearest outside walkthrough of what the proposed rule actually does, and my source for the G2211 modifier structure and the scope of the RFIs. Hananoki JF, Bucshon LD, Franco MA. "CMS Issues CY 2027 Medicare Physician Fee Schedule Proposed Rule." Holland & Knight Alert, July 20, 2026. hklaw.com

The hospital notification requirement most clinicians don't know exists, along with the fine print that explains why it doesn't solve the Dorothy problem. CMS interpretive guidance covering the three required data elements, the "reasonable effort" standard, the conformance condition, and the allowance for daily batching. Centers for Medicare & Medicaid Services, "Admission, Discharge, and Transfer Patient Event Notification Conditions of Participation (42 CFR 482.24(d), 482.61(f), and 485.638(d))." cms.gov

How the notification actually gets from a hospital to a practice, who pays for it, and why enforcement is weaker than the phrase "Condition of Participation" suggests. This is my source for the three circumstances in which CMS does not expect a notification to be sent, for CMS permitting a hospital to comply through a single network, and for the fact that termination from Medicare is the only enforcement remedy available with no authority to levy monetary penalties. Manifest MedEx, "New CMS Admission, Discharge, and Transfer (ADT) Event Notification Requirements: What California Hospitals Need to Know." manifestmedex.org

Confirmation that hospitals are not required to deliver notifications into a physician's inbox, and the Atrius Health experience of one admission generating six or more messages. American Medical Association, "Are hospitals required to deliver ADT notifications directly to a physician's EHR inbox?", Debunking Regulatory Myths series. ama-assn.org

Where the notification requirement came from, and also where patient data access began. This is the rule that created both the ADT Conditions of Participation and the original Patient Access API discussed in Section VII. Centers for Medicare & Medicaid Services, "CMS Interoperability and Patient Access Final Rule (CMS-9115-F)," published May 1, 2020, with an applicability date of April 30, 2021 for the patient event notification Conditions of Participation. cms.gov · The final rule at 85 FR 25510: federalregister.gov

Everything in Section VII about the mandatory side of patient data access, and my source for the four interfaces due January 1, 2027. The rule expands the Patient Access API to include prior authorization decisions and adds Provider Access, which sends a patient's data to her treating clinicians unless she opts out. It binds Medicare Advantage organizations, Medicaid and CHIP programs, and qualified health plan issuers on the federally facilitated exchanges, and does not reach Original Medicare. Centers for Medicare & Medicaid Services, "CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F)," released January 17, 2024. cms.gov · Fact sheet: cms.gov

The voluntary side, and my source for the pledge count, the Medicare App Library, and "Kill the Clipboard." CMS describes the effort in its own words as a movement rather than a mandate, which is the whole point of that passage. Centers for Medicare & Medicaid Services, "Health Technology Ecosystem." cms.gov · First wave launch, April 9, 2026: cms.gov

The transitional care management timing requirements, and my source for the two-business-day clock. The 30-day period begins the day of discharge from an acute hospital, IRF, LTCH, psychiatric hospital, skilled nursing facility, or observation stay. Centers for Medicare & Medicaid Services, "Transitional Care Management Services," MLN Booklet 908628, August 2025. cms.gov

Everything in Section III about what CHI and PIN actually require, including the initiating visit, the annual consent, the seven training competencies, the Part B coinsurance, and the fact that a community-based organization has no way to bill Medicare directly. Centers for Medicare & Medicaid Services, "Caregiver Training (CTS), Community Health Integration (CHI), Principal Illness Navigation (PIN), and Physical Activity and Nutrition Risk Assessment Services: Frequently Asked Questions." cms.gov

The newest care management bundle, and the one that makes panel risk-stratification and post-discharge outreach billable service elements. American Academy of Family Physicians, "Using Advanced Primary Care Management Services Codes G0556, G0557 and G0558," including the 2025 national allowable amounts of $15.20, $48.84, and $107.07 per patient per month. aafp.org · CMS program requirements: cms.gov

Context for Section V: how many clinicians and beneficiaries are actually inside an accountable care relationship today, and what the Shared Savings Program returned in its most recent performance year. Centers for Medicare & Medicaid Services, "2026 Medicare Accountable Care Organization Initiatives Participation Highlights," February 4, 2026. cms.gov

The ten-year model that replaces ACO REACH beginning January 1, 2027, aimed at the small and independent practices that have historically stayed out. Centers for Medicare & Medicaid Services Innovation Center, "Long-term Enhanced ACO Design (LEAD) Model." cms.gov

The empirical backing for Section IV, and my source for the 19 percent and 21 percent figures. A cross-sectional study of 80,246 primary care physicians found MIPS scores inconsistently associated with both process and outcome measures, with two process measures so topped out that the median physician scored 100 percent. Bond AM, Schpero WL, Casalino LP, Zhang M, Khullar D. "Association Between Individual Primary Care Physician Merit-based Incentive Payment System Score and Measures of Process and Patient Outcomes." JAMA. 2022;328(21):2136-2146. pubmed.ncbi.nlm.nih.gov · Free full text: pmc.ncbi.nlm.nih.gov · The accompanying editorial is worth reading on its own: McWilliams JM. "Pay for Performance: When Slogans Overtake Science in Health Policy." JAMA. 2022;328(21):2114-2116. pubmed.ncbi.nlm.nih.gov

What the compliance machinery costs a practice, and my source for the $12,811 and the 202 hours. Khullar D, Bond AM, O'Donnell EM, Qian Y, Gans DN, Casalino LP. "Time and Financial Costs for Physician Practices to Participate in the Medicare Merit-based Incentive Payment System: A Qualitative Study." JAMA Health Forum. 2021;2(5):e210527. pmc.ncbi.nlm.nih.gov · pubmed.ncbi.nlm.nih.gov

What a hospital actually risks by ignoring what happens after discharge. The penalty is capped at three percent of base operating DRG payments and applies to six condition- and procedure-specific measures. Centers for Medicare & Medicaid Services, "Hospital Readmissions Reduction Program," established by Section 3025 of the Affordable Care Act and codified at Section 1886(q) of the Social Security Act, effective FY 2013. cms.gov

The tax doctrine that healthcare measurement never built, and my source for the close of Section IV. Section 1409 codified the economic substance doctrine at Section 7701(o) of the Internal Revenue Code, providing that a transaction is respected only if it changes the taxpayer's economic position in a meaningful way apart from its tax effects and the taxpayer had a substantial purpose beyond them. Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, § 1409. Statutory text, hosted by HHS: hhs.gov · IRS guidance on how the doctrine is applied: Notice 2014-58. irs.gov

How employer-sponsored insurance actually happened, including the 1942 wage control exemption, the 1943 IRS ruling, and the 1954 codification at Section 106. Also a useful caution that the "it was all a tax accident" story often gets told too simply. Congressional Research Service, "The Tax Exclusion for Employer-Provided Health Insurance: Issues for Congress," RL34767, updated January 4, 2011. everycrsreport.com

*Disclaimer: All opinions and ideas expressed in this article are solely mine and none represent a recommendation or should be viewed as advisement of any kind to anyone to do anything.*