Cracking the Code: Unlocking the Power of the Value-Based Exceptions and Safe Harbors

• October 31, 2025

Scott Strickland, Shareholder, Hall Render Killian Heath & Lyman PC, Jim Carr, Co-Founder and Partner, InHealth Advisors, and Rachel Polzin, Assistant General Counsel, SSM Health, discuss the value-based enterprise (VBE) framework and the associated exceptions and safe harbors. They cover why the uptick in the framework has been a bit slower than anticipated, ways for health care organizations to take advantage of the VBE exceptions and safe harbors to mitigate risk, the future of traditional co-management arrangements, integrating new compliance processes, and how the Transforming Episode Accountability Model might promote the adoption of VBE. Scott, Jim, and Rachel spoke about this topic at AHLA’s 2025 Annual Meeting in San Diego, CA.