Compliance & Legal

Compliance risk in VBC is shifting from traditional coding/audit exposure toward governance of AI, interoperability, and delegated operations: Innovaccer’s governance-led AI positioning underscores that population health and risk adjustment tools now need defensible controls, audit trails, and model oversight to withstand payer, CMS, and OIG scrutiny in value-based arrangements. At the same time, provider–payer conflict is intensifying in Medicare Advantage, with Jefferson Health suing Aetna over MA payment policy, signaling that contract enforcement, claims adjudication rules, and federal MA compliance standards are becoming strategic issues for health systems managing downside risk. Interoperability governance is also becoming a structural constraint on VBC execution, as nationwide exchange networks face pressure to support broader data-sharing responsibilities without mature governance models, creating operational and legal friction for ACOs and population health programs dependent on timely cross-network data.