Fraud and Abuse Waivers

The Secretary of the U.S. Department of Health and Human Services issued waivers of certain federal fraud and abuse laws for ACOs participating in the Medicare Shared Savings Program (“MSSP”) (see “Final Waivers in Connection With the Shared Savings Program” (See 80 Fed. Reg. 66,726 (Oct. 29, 2015)) (the “Final Rule”)). Pearl Care 1, LLC (the “ACO”) is currently participating in the MSSP pursuant to a Participation Agreement with the Centers for Medicare & Medicaid Services (“CMS”). Pursuant to the Final Rule, the ACO seeks ACO Participation waiver protection for the arrangements described below.

Disclosed Arrangements for the ACO Participation Waiver

On January 29, 2026, the ACO Board of Directors made a bona fide determination that the following arrangement is reasonably related to the purposes of the MSSP (all arrangements were subject to Board approval and, as such, were not final unless and until approved by the ACO Board of Directors):

The ACO entered into Preferred Provider Network Agreements with each of the providers listed below, effective January 1, 2026. Under these agreements, the providers deliver one of the following services: skilled nursing, home health, hospice, outpatient surgical, nutrition counseling, physical therapy, and laboratory services to the ACO's assigned Medicare fee-for-service beneficiaries, with accountability for quality measure performance and cost efficiency aligned with the purposes of the MSSP.

A list of each Preferred Provider subsidiary participating in this program can be found here: MSSP Website Disclosure Preferred Provider List