Now Accepting Design Partners: Building Dual-Statute Compliance Infrastructure

Five hospital compliance programs, one six-month cohort, building the response to the April 2026 OIG shift. Applications open July 15, 2026.

Published July 1, 2026 6 minute read By the ArrowISE team

What we're doing

ArrowISE is accepting five hospital compliance programs into a six-month design partner cohort. Applications open July 15, 2026, and the cohort begins August 15, 2026. Partners get free access to ArrowISE for the full cohort, direct founder access, and locked conversion pricing at 50% off the standard enterprise rate. In exchange, they use the product on real physician arrangements, give structured feedback, and agree to serve as a reference at cohort end.

The full criteria, timeline, and application are on the design partner program page. This post explains why the program exists now, what we have built, and why a design partner cohort — rather than a paid pilot — is the right structure for this stage.

The compliance landscape since April 2026

On April 23, 2026, the OIG updated its fraud-and-abuse FAQs (revised FAQ 4 and new FAQ 17) to restate that Stark Law compliance and fair market value do not, by themselves, shield an arrangement from the Anti-Kickback Statute, and that AKS exposure turns on intent. The law did not change, but the guidance removed a common shortcut. A program that documents a fair market value opinion and a satisfied Stark exception, and stops there, has addressed one statute and left the intent-based one unexamined. We wrote about this in FMV Alone Won't Save You.

The practical consequence is that the dual-statute framing — Stark defensibility alongside Anti-Kickback intent exposure — is now the operational standard, not the sophisticated one. A compliance program that scores only FMV and exception fit is demonstrably behind the regulator's stated position.

This is arriving at a difficult time for the people who own the risk. Compliance budgets remain flat at roughly 0.5–2% of organizational revenue (per the 2025 Healthcare Compliance Benchmark Survey) while regulatory expectations accumulate. That gap is not sustainable with spreadsheet-based arrangement tracking, which captures data but cannot produce the contemporaneous, dual-statute evidence an investigation would demand — a problem we detailed in The Spreadsheet Gap.

None of this is theoretical. Physician financial relationships remain at the center of federal enforcement — from Stark-driven matters like Community Health Network to Anti-Kickback matters arising from physician remuneration — and the enforcement library we maintain catalogs the recurring failure modes. The through-line is consistent: programs that could not produce contemporaneous, arrangement-by- arrangement evidence under time pressure.

What ArrowISE has shipped in response

ArrowISE is compliance infrastructure for physician arrangements. On each arrangement it computes a Defensibility Index — a weighted score covering FMV currency, safe-harbor completeness, OIG exclusion status, external assessment currency, and a proprietary risk factor. The methodology is documented in full on the methodology page.

In June 2026 we shipped the second half of the dual-statute picture: an AKS Exposure score that sits beside the Defensibility Index and measures intent posture rather than pricing. It combines auto-derived signals (FMV positioning, compensation relative to the FMV opinion, safe-harbor gaps) with attested intent factors (whether compensation is independent of referral volume or value, whether remuneration is limited to the written agreement, whether conduct matches the agreement).

Around those two scores the product provides evidence packets, board reports, an approval workflow engine, an enforcement-case library, and a tamper-evident audit trail. The audit trail is tamper-evident in a specific sense: each arrangement's state is captured in a deterministic composite hash, so a record cannot be quietly revised after the fact. That is the difference between a system that stores what a program knows and one that can prove what it knew, and when — the property that matters most when the documentation itself is the subject of an inquiry.

The infrastructure is built. The design partner cohort exists to test it in real compliance workflows, at real hospitals, before general availability.

Why a design partner cohort, not a pilot program

The distinction matters, and it is worth being direct about. A pilot is procurement-shaped. It involves a budget line, a vendor risk assessment, procurement approval, and usually a term commitment — months of process before a compliance officer can evaluate whether the tool is useful.

A design partnership is a working relationship. There is no cost during the cohort and no procurement to clear. In place of a purchase order there is a mutual NDA, a defined feedback cadence, and a reference commitment. For a compliance program willing to invest about 15 hours over six months, the design partner path delivers material value while bypassing the procurement cycle entirely.

Conversion at cohort end is at a locked rate: $99 per month for 24 months — 50% off the standard $198 per month enterprise rate. The locked price is a guarantee, not a required 24-month commitment. The substantive give from the partner side is the reference commitment: a mutual case study, a testimonial, and availability as a named reference, all subject to the partner's approval on published content. That exchange — early access and influence over the roadmap in return for feedback and a reference — is the whole basis of the program.

"Design partner" is meant literally. Cohort partners see the roadmap early and shape it: the attested intent factors, the evidence-packet format, the workflow states, and the board-report structure are all areas where a compliance officer's daily reality should drive the product more than a founder's assumptions can. Five programs, engaged over six months, is enough signal to build against and small enough that each voice carries real weight.

We are also being deliberate about the stage. ArrowISE is pre-general-availability, and the honest framing is that the first cohort trades polish for influence and price. Partners will encounter rough edges; their reports are how those edges get filed down before the product reaches a wider market. That is the trade the program makes explicit rather than hiding.

Who the first cohort is for

The cohort is built for US-based hospitals and health systems with active federal healthcare program participation, a minimum of 25 active physician arrangements, and a dedicated compliance function with an identified internal champion and an executive sponsor. Recent OIG activity, a growing arrangement portfolio from M&A or new PSAs, or existing spreadsheet-based tracking are strong-fit signals. Payer-only organizations, private-pay concierge practices, and paper-only compliance operations are not a fit for the first cohort. The full criteria are on the design partner program page. The two roles that matter most are the internal champion who will use the product daily and the executive sponsor who can protect the time; cohorts stall when either is missing, which is why both are prerequisites rather than nice-to-haves.

How to apply

Applications open July 15, 2026. The application is short: your role, your hospital's approximate size, current arrangement volume, one sentence on why now, and your identified executive sponsor and internal champion. Every applicant receives a decision within five business days, whether accepted or not.

Full details and the application are on the design partner program page, or email lance@getarrowise.com directly. This is the cohort building the response to the April 2026 OIG shift, and this is who we want to build it with.

Sources: HHS-OIG, "General Questions Regarding Certain Fraud and Abuse Authorities" FAQ (revised FAQ 4 and new FAQ 17, April 23, 2026); 2025 Healthcare Compliance Benchmark Survey. ArrowISE has no affiliation with HHS-OIG, CMS, or any government agency.