CMS TEAM Compliance Risks Hiding in Plain Sight: Gain Sharing, Data Governance & AI | Ep. 4

CMS TEAM compliance isn't just about episode payments — the highest-stakes risks are the ones most hospitals aren't talking about yet: gain sharing agreements, data governance failures, and ungoverned AI. Rainfall Health's VP of Clinical Implementation Robby Wallace and VP of Compliance and Care Coordination Marla Merkle sit down with Paul Uhrig — former Chief Legal & Digital Health Officer at Bassett Healthcare Network, former Chief Administrative Officer at SureScripts, and member of the R.A.I.N. Advisory Committee — to break down what 721 mandated hospitals need to have documented, structured, and governed before regulators come knocking.

Paul has lived through the e-prescribing and meaningful use mandates firsthand. His message: the government follows through. History says so.

In this episode:
- Why gain sharing arrangements must be documented before care begins — not after
- How Anti-Kickback Statute and Stark Law apply to CMS TEAM downstream payments
- What the 2020–2021 OIG safe harbor for CMS-sponsored models actually requires
- Why your vendor's data use agreement may have loopholes you haven't found yet
- How information blocking and HIPAA create a compliance balancing act under TEAM
- Where AI governance is going wrong in health systems right now
- Why the e-prescribing mandate is the closest historical parallel to TEAM enforcement
- What Paul recommends every hospital prioritize in the next 90 days

Paul Uhrig is a healthcare attorney and digital health executive with decades of experience at the intersection of health law, regulatory compliance, and technology. He served as Chief Legal & Digital Health Officer at Bassett Healthcare Network and as Chief Administrative Officer at SureScripts, where he lived through the federal e-prescribing and meaningful use mandates in real time. Paul sits on the R.A.I.N. Advisory Committee at Rainfall Health.

Rainfall Health is the first and only recognized standard for Medicare-mandated models like CMS TEAM. Our R.A.I.N. Compliant™ platform helps the 721 IPPS hospitals mandated under the Transforming Episode Accountability Model quantify, capture, and maximize Medicare reimbursements across all 5 surgical episodes and the mandatory 30-day post-discharge window — with R.A.I.N. Compliant status achievable in approximately 10 weeks.

Read the full CMS TEAM Guide: https://www.rainfallhealth.com/cms-team/
Learn more: https://www.rainfallhealth.com