St. Luke’s Shared Savings Plan, LLC
Public Website Reporting on MSSP EHR Waiver use

St. Luke’s Shared Savings Plan, LLC (the “ACO”) is currently participating in the Medicare Shared Savings Program (“MSSP”) pursuant to a Participation Agreement with the Centers for Medicare & Medicaid Services (“CMS”) entered into effective January 1, 2018,. The Department of Health & Human Services, through an interim final rule issued November 2, 2011 (76 Fed. Reg. 67992 (Nov. 2, 2011)) and a final rule issued October 29, 2015 (80 Fed. Reg. 66726 (Oct. 29, 2015)) by CMS and the Office of Inspector General (“OIG”), has provided for a waiver of federal fraud and abuse laws for arrangements entered into by an accountable care organization participating in the MSSP that are reasonably related to the purposes of the MSSP (the “ACO Participation Waiver”). The ACO Participation Waiver protects only those arrangements that meet waiver criteria established by CMS and the OIG, including a requirement that all arrangements entered into under the ACO Participation Waiver be publicly disclosed.

In accordance with the public disclosure requirement of the ACO Participation Waiver, the following describes arrangements involving the ACO and its ACO participants and ACO providers/suppliers for items, services, goods or facilities used to create, develop and/or operate the ACO, and also to support the ACO in its efforts to achieve the goals of the MSSP.

The ACO’s Board of Managers has duly authorized the arrangements below and made a bona fide determination that each arrangement is reasonably related to the purposes of the MSSP because the arrangements will improve care management and coordination for Medicare beneficiaries assigned to the ACO, enhance its population health and quality improvement initiatives, and support efforts to implement redesigned care processes that promote accountability for the quality, cost, and overall care delivered to the ACO’s patients.

1. On June 6, 2018, the ACO Board of Managers approved an arrangement whereby ACO and St. Luke’s Health Network, Inc. d/b/a St. Luke’s University Health Network (“SLUHN”), an ACO participant, will provide certain electronic health record technology and support to physicians and physician practices that include physicians, who participate in the MSSP (the “Practices”). In connection with this arrangement, SLUHN and the ACO have executed and/or will execute Electronic Health Record Subsidy Agreements with Practices to provide support with respect to adoption of electronic health record technology for population health activities.

Future arrangements, and modifications to current arrangements, will be added to this list in accordance with CMS requirements.