"Implementing a value-based contract that ties payments to quality metrics or population health outcomes creates several fiduciary questions. Does shifting risk to a provider expose plan participants to narrower networks or limited access that may conflict with fiduciary obligations? How should fiduciaries evaluate whether the incentive structures truly benefit plan participants rather than merely reduce employer costs? ... Using standardized CMS data sets minimizes ambiguity and improves objective benchmarking. From a legal point of view, incorporating CMS data sets requires careful implementation. "  MORE >>