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Stephen Bentfield

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Stephen Bentfield is a partner and a member of the firm’s Health Care Group. Stephen counsels health care organizations on a wide range of health care regulatory and transactional matters. His regulatory experience includes helping clients with issues such as fraud and abuse enforcement risk analysis and mitigation, organizational compliance programs and policies, managed care, value-based care, reimbursement, licensure, and state regulatory issues. On the transactional side, Stephen has extensive experience drafting contracts, advising on deal structuring and negotiation, including the creation of joint ventures and other new corporate structures, as well as mergers and acquisitions.

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On May 12, 2025, the Center for Medicare and Medicaid Innovation (Innovation Center) released a new strategy to outline the Trump Administration’s vision to test alternative payment models in Medicare and Medicaid.

Abe Sutton, Director of the Innovation Center and Deputy Administrator for the Centers for Medicare & Medicaid Services (CMS), authored a white paper titled, “CMS Innovation Center Strategy to Make America Healthy Again,” which provides an updated vision for the Innovation Center. A core feature of this updated strategy is its focus on preventative care to stave off certain conditions that can help reduce disease risk and costly treatments. The white paper states that the Innovation Center will build on the work done in the last 15 years and test new models that would “improve quality and outcomes and reduce costs for taxpayers” and empower people to “achieve their own health goals and Make America Healthy Again.” Recognizing that some previous Innovation Center models have shown promise for supporting preventive care, many did not meet the criteria for nationwide expansion and widespread adoption. Director Sutton’s white paper outlines three strategic pillars: 1) promote evidence-based prevention; 2) empower people to achieve their health goals; and 3) drive choice and competition for people.Continue Reading CMS Innovation Center Releases New Strategy In Line With “MAHA” Agenda

In January 2024, the Centers for Medicare and Medicaid Services (CMS) announced a new innovation care delivery model that seeks to bridge the gap between behavioral and physical health. The Innovation in Behavioral Health (IBH) Model aims to improve the quality of care and behavioral and physical health outcomes for adults with moderate to severe mental health conditions and substance use disorders (SUDs). The IBH Model will service beneficiaries who are enrolled in Medicare and Medicaid, including those who are dual eligible.[1] These populations experience higher than average rates of mental health conditions or SUDs, or both, highlighting the importance of a model that integrates behavioral and physical healthcare as well as addressing health-related social needs (HRSN).[2]Continue Reading CMS Notice of Funding Opportunity for the Innovation in Behavioral Health Model Open Until September 9, 2024

In March 2024, the Centers for Medicare & Medicaid Services (CMS) released a new voluntary model called the ACO Primary Care Flex Model (ACO PC Flex Model). This model focuses on primary care delivery within the Medicare Shared Savings Program (MSSP), which is Medicare’s longest-running program whereby health care practitioners and other providers and suppliers form an Accountable Care Organization (or ACO) to provide coordinated, high quality care to Medicare beneficiaries. Continue reading to learn more about the ACO PC Flex model.Continue Reading An Overview of the ACO Primary Care Flex (ACO PC Flex) Model