Recently in Accountable Care Organizations Category

October 20, 2011

BREAKING NEWS: Final Accountable Care Organization ("ACO") Regulations Released

The long-awaited final regulations for the Medicare Shared Savings Program ("MSSP") were released today. The MSSP was implemented by Section 3022 of the Patient Protection and Affordable Care Act and is the program in which ACOs may participate to receive shared savings.

In addition to the release of the Final Rule on October 20, the Office of Inspector General ("OIG") also released its interim final rule entitled Final Waivers in Connection with the Shared Savings Program; the Federal Trade Commission ("FTC") and the Department of Justice ("DOJ") jointly released the Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program; and the Internal Revenue Service ("IRS") issued a fact sheet entitled Tax-Exempt Organizations Participating in the Medicare Shared Savings Program Through Accountable Care Organizations.

Continue reading "BREAKING NEWS: Final Accountable Care Organization ("ACO") Regulations Released" »

September 15, 2011

CMS and OIG Respond to Finance Committee's Letters Regarding PODs

In July, the HEALTH LAW ATTORNEY BLOG reported on five U.S. Senators asking the Office of Inspector General ("OIG") and the Centers for Medicare and Medicaid Services ("CMS") to issue guidance on physician owned distributorships ("PODs") (or, sometimes referred to as physician owned intermediaries ("POIs")). The OIG and CMS have issued their responses.

By way of brief background, a POD is an arrangement in which, according to the U.S. Senate Committee on Finance ("Finance Committee"), "allow physician investors to purchase ownership shares in an entity that, in turn, purchases or serves as a medical device distributor for the products the physician utilizes in surgery." Because of lack of industry guidance on the potential for fraud and abuse violations, the Finance Committee issued Physician Owned Distributors (PODs): An Overview of Key Issues and Potential Areas for Congressional Oversight wherein it recommended letters be sent to the OIG and CMS articulating its concerns and asking for guidance.

On June 9, 2011, the Finance Committee issued two letters--one to the OIG and one to CMS. In its letter to the OIG, the Finance Committee sought guidance on how PODs fit, or don't fit, within the confines of the Anti-Kickback Statute ("AKS"). In so doing, the Finance Committee insisted that

[I]t is incumbent upon the OIG to address this rapidly evolving healthcare market issue by conducting an inquiry into PODs and their current structures and activities and then reporting to us the results of such an inquiry, along with your recommendations for further action should be taken by the OIG and Congress to effectively address the patient and program risks presented by PODs.

In its letter to CMS, the Finance Committee sought guidance on the Physician Payments Sunshine Act ("Sunshine Act") and accountable care organizations ("ACOs"). In seeking guidance on these issues, the Finance Committee requested CMS
[C]losely examine the physician ownership and investment interests presented by PODs and ensure that those are addressed as you finalize the reporting requirements of the Sunshine Act. This would mean that the distribution model of these physician owned companies would need to be included as CMS develops a final definition of "applicable manufacturers" and "applicable Group Purchasing Organizations (GPOs)."

The Finance Committee continued in its letter to ask CMS to take PODs into consideration when issuing the final ACO regulations:
CMS should take into account the POD models when developing its final regulation to ensure that qualification and oversight of ACOs protect against potential abuses posed by PODs. The final rule should prohibit ACOs from purchasing products or services from entities that are owned by physicians participating in the ACO. Ownership should be deemed to exist if the physician receives any remuneration (cash, equity, options, profits, dividends, etc.) from the entity supplying the product or service. It should be made clear that waivers of Stark and Anti-Kickback laws should not extend to PODs.

On August 10, 2011, CMS replied to the Finance Committee's letter stating that it will take the Finance Committee's letter into consideration when developing the Sunshine Act's proposed regulations. CMS also stated that the period for submitting comments on the ACO Waiver Designs proposed regulations ended on June 6, 2011 and that it was reviewing the comments it received and was developing the final ACO regulations with respect to its waiver authority.

More significant, however, is the September 13, 2011 OIG response to the Finance Committee. The OIG revealed that, pursuant to a meeting with the Finance Committee on July 19, it is "initiating a review of PODs that will seek to determine the extent to which PODs provide spinal implants purchased by hospitals." The OIG stated that it will be a national study of hospitals that bill Medicare for spinal surgery. After the review, the OIG intends to establish:


  • How widespread PODs are;

  • What services PODs offer to hospitals;

  • Whether PODs save hospitals money in the acquisition of implants; and

  • Whether the PODs identified in the review are associated with high use of spinal implants.


With respect to the AKS concerns raised by the Finance Committee, the OIG reminds the Finance Committee that such determinations are extremely fact specific and, therefore, the "OIG's ability to issue guidance about the application of the statute to these business structures is limited." The OIG also reminded the Finance Committee that when it evaluates the legality of situations in which referring physicians can earn a profit--including through an investment in an entity for which s/he generates business--it considers certain factors, including:

  • The terms under which a physician may invest in the entity;

  • The terms under which a physician-owner may be required to divest his/her ownership interest;

  • The actual return or projected return on the physician's investment; and

  • The amount of revenues generated for the entity by its physician-investors.


The OIG did not state how long its review would last, but providers and suppliers should be aware that the OIG is beginning to focus its attention on this issue and that guidance will be forthcoming.

Continue reading "CMS and OIG Respond to Finance Committee's Letters Regarding PODs" »

June 14, 2011

AMA Submits Comments to CMS Regarding ACO Proposed Rule

On Friday, June 3, the American Medical Association ("AMA") submitted its comments concerning the Accountable Care Organizations ("ACOs") Proposed Rule (the "Proposed Rule") to Donald Berwick, the Centers for Medicare and Medicaid Services ("CMS") Administrator. The Proposed Rule was issued by CMS on March 31, 2011. In its comments, AMA provided its views and recommendations regarding the Proposed Rule while reiterating its belief that a successful ACO model "can be an effective tool to improve quality, manage care coordination, reduce health care costs, and create a supportive environment for practicing physicians." However, AMA urged CMS to issue an interim final rule to allow for the flexibility to change and improve the regulations as more information about the ACO model becomes available.

AMA addressed a number of issues in its extensive comments. First, AMA suggested changes to the proposed ACO payment and risk structure. AMA recommended the inclusion of at least one shared savings only option which would not include a mandatory shared loss provision in order to encourage participation by a greater variety of practices. AMA believes that without such an option participation could be unnecessarily limited because providers already have an incentive to become more cost-effective without the down-side risk provision. In the alternative, AMA suggested that the shared savings only option should, at the very least, be extended to smaller ACOs. AMA also urged CMS to allow health care providers to bill Medicare for procedures which are not currently billable under payment options which embrace down-side risk. AMA also suggested that ACOs share in a portion of all savings that are achieved without a minimum savings threshold, and that CMS increase the savings percentage ACOs are eligible to receive, especially at the beginning of the program. AMA also urged the removal of the withholding and line of credit provision of the Proposed Rule and suggested adjustments to the expenditure benchmark based on the health status of an ACO's patients during the performance period. Lastly, AMA urged the exclusion of the care costs for outlier patients from the savings calculation.

Next, AMA urged the inclusion of a number of transitional ACO models in order to encourage small and solo practice participation in ACOs. AMA urged "CMS to allow these alternative ACOs to share in a percentage of all savings that are achieved, rather than simply sharing in the savings above the minimum savings threshold proposed in the rule."

AMA also urged CMS to accept a more flexible approach to ACO beneficiary assignment. At the very least, AMA urged CMS to strike a balance between prospective and retrospective attribution. However, AMA stated that ideally "CMS should adopt a prospective approach that allows patients to volunteer to be part of the ACO and permits the ACOs to know up-front those beneficiaries for whom the ACO will be responsible." AMA believes that these proactive efforts are crucial in order to encourage and educate beneficiaries to behave in ways which will make ACOs successful.

Next, AMA expressed its views regarding the quality measures and other reporting requirements found in the Proposed Rule. AMA urged CMS to "(1) align quality measure domains and quality measures across its programs (including the ACO, Electronic Health Record [EHR] Incentive Program, and PQRS) and reduce the number of required measures in the initial years; (2) provide ACOs with some flexibility of measure selection; (3) reconsider data submission methods; and (4) support clinical quality registries as a significant data submission method." Among the numerous specific suggestions, AMA urged that CMS publish the required quality measures at least 90 days prior to the initial effective date of the ACO program and modify the 100 percent reporting on all measures requirement which is currently necessary under the proposed rule to qualify providers for a share of the savings.

AMA went on to address a number of other issues. AMA was pleased with the overall ACO governance structure proposal, but suggested some differing requirements for oversight of ACOs. AMA went on to disagree with the exclusion of rural health clinics from the proposed plan. Next, AMA agreed with CMS' overall attempt to propose waivers of federal program integrity laws in an effort to "test new payment models and methods that improve patient outcomes and promote value" and suggested a few improvements. Subsequently, AMA also urged CMS to consider its letter to the Federal Trade Commission ("FTC") and the Department of Justice ("DOJ"), which it recently wrote in response to the Statement of Antitrust Enforcement Policy, alongside the comments that AMA has provided to CMS. Lastly, AMA further urged CMS to ensure that tax-exempt ACOs may distribute the shared savings to ACO-participating providers or stakeholders without losing the ACO's tax-exempt status.

For the complete text of the comments, please click here.

Continue reading "AMA Submits Comments to CMS Regarding ACO Proposed Rule" »

June 13, 2011

Health Insurers Diversify in Wake of Industry Reform

The national health care reform, the implementation of which effectively requires a shift of health insurer spending more heavily towards medical care, is projected to reduce insurance profit margins to approximately 3% to 5%. This is a substantial decline considering these margins historically averaged around 7% to 8%. As a result, major health insurers in the United States are diversifying their businesses to include new partnerships and acquisitions that allow the companies to provide health information technology ("HIT"), take part in accountable care organizations ("ACOs"), and employ doctors directly.

The HIT market, in particular, is alluring to health insurers. Approximately 20% of managed-care business deals since 2010 involved HIT firms. Large profit margins reported by some companies with a presence in the HIT market (in excess of 20% in some instances), brought about by relatively low overhead, contribute to the appeal of these acquisitions. Interest in HIT businesses is fueled even further by the $27 billion available to doctors and hospitals for record computerization from the federal government.

Further, health insurers are participating in ACO formation projects and the direct employment of physicians. Their participation in creating ACOs seems a natural complement to plans' core business considering that under the ACO plan the financial risk of patient care is partly transferred from the insurers to doctors and hospitals. Absent a change in the federal ACO proposed regulations, however, the 25% cap on ownership by non-providers might militate against ownership in ACOs. The direct employment of physicians, on the other hand, might prove financially beneficial to insurers while reducing patient costs, especially if the predicted shortage of primary-care doctors is not meaningfully addressed.

The recent health insurer diversification triggers concerns among certain health care policy makers, namely as a result of the possibility that such efforts will take attention from the core of each insurer's business. This, however, has not deterred a number of major U.S. health insurers from attempting to diversify, and the expectation is that the trend will continue.

Continue reading "Health Insurers Diversify in Wake of Industry Reform" »

June 6, 2011

AMA Submits Comments to CMS Regarding ACOs, Calls for Interim Final Rule

On Friday, June 3, the American Medical Association (AMA) submitted its comments to Donald Berwick of the Centers for Medicare and Medicaid Services (CMS) regarding CMS' proposed rule for Accountable Care Organizations (ACOs). In its opening remarks, the AMA states the following:

The AMA is pleased to provide our views and recommendations for revising the proposed rule so that the ACO model can be tested in a broad spectrum of physician practices. We are confident that a well-developed ACO model can be an effective tool to improve quality, manage care coordination, reduce health care costs, and create a supportive environment for practicing physicians. Since this is a completely new Medicare delivery and payment model, the AMA urges CMS to issue an interim final rule, rather than a final rule, so that CMS maintains the flexibility to modify and improve the ACO regulations as the agency learns more about this model.

In addition to calling for an interim final rule, within its 31 pages of comments, the AMA submitted comments on issues including:
• The ACO payment and risk structure,
• The need for additional payment models,
• Beneficiary assignment,
• Quality measures and other reporting requirements,
• ACO governance structure,
• Rural health clinics,
• Waivers of federal program integrity laws,
• Antitrust issues, and
• Private inurement.

Continue reading "AMA Submits Comments to CMS Regarding ACOs, Calls for Interim Final Rule" »

June 2, 2011

AMA Submitted Comments on FTC/DOJ ACO Antitrust Enforcement Policy

On May 26, the American Medical Association (AMA) submitted a letter to Donald Clark--the Federal Trade Commission (FTC) Secretary--in response to the proposed FTC and Department of Justice (DOJ) Statement of Antitrust Enforcement Policy regarding accountable care organizations (ACOs). The AMA opened its letter by urging the FTC to consider its comments insofar as "the ACO requirements and antitrust clearance process could have a significant and negative impact on the ability of physicians, hospitals, and other eligible ACO entities to successfully form and participate in the ACO models." Moreover, the AMA emphasized the need to protect physician-led ACOs as the current regulations will have the "unintended consequence" of promoting hospital consolidation of physician markets through the acquisition of physician practices. According to the AMA, such a trend towards practice acquisition would thereby exert pressure on physicians to become employed or sell their practices to a hospital in order to participate in ACOs under the Shared Savings Program.

The AMA has stated it will submit its comments to the Centers for Medicare and Medicaid Services (CMS) on the ACO proposed rule on June 6. Please visit THE HEALTH LAW ATTORNEY BLOG for updates on the AMA's comments as well as other developments regarding ACOs.

Continue reading "AMA Submitted Comments on FTC/DOJ ACO Antitrust Enforcement Policy" »

May 27, 2011

ACO Proposed Rule's Program Integrity Includes Mandatory Compliance Plans

In its proposed rule for accountable care organizations ("ACOs"), the Centers for Medicare and Medicaid Services ("CMS") includes mandatory compliance plans as an element of its ACO-program integrity efforts. The compliance plan must include at least the following elements:

• A designated compliance officer who is not legal counsel to the ACO and who reports directly to the ACO's governing body

• Mechanisms for identifying and addressing compliance problems related to the ACO's operations and performance

• A method for employees or contractors of the ACO or ACO providers/suppliers to report suspected problems related to the ACO

• Compliance training of the ACO's employees and contractors

• Requirement to report suspected violations of the law to an appropriate law enforcement agency.


Since the Patient Protection and Affordable Care Act's enactment, adoption of compliance plans--both for ACOs and generally--has become mandatory for participation in Medicare, Medicaid and the Children's Health Insurance Program.

Continue reading "ACO Proposed Rule's Program Integrity Includes Mandatory Compliance Plans" »

May 19, 2011

Potential ACOs Reluctant to Participate Under Proposed Rule

During late March, the Centers for Medicare and Medicaid Services ("CMS") proposed a rule regarding Accountable Care Organizations ("ACOs") and the Medicare Shared Savings Program, which will make payments of shared savings to ACOs ("Proposed Rule"). The Proposed Rule describes the amount of financial risk the participants will face and the type of data the providers will be expected to collect under CMS' current vision for the program. Many believe in the ACO concept of higher quality care at reduced costs. However, the complaints regarding the actual Proposed Rule are numerous and multi-faceted. Even the high-profile health care centers such as the Cleveland Clinic, the Mayo Clinic, and Intermountain Healthcare, which were used as inspirations for the Medicare Shared Savings Program and its ACOs, are hesitant to participate. Among other obstacles, the financial investment that providers will need to dedicate to participate in the Medicare Shared Savings Program under the Proposed Rule (e.g., to add technology and staff necessary to track the quality data to be collected) may prove to be a barrier to their participation. CMS officials are aware of the issues raised by the Proposed Rule. Dr. Donald Berwick, the Administrator of CMS, has expressed CMS' desire and commitment to cooperate with health care providers to work out the problems.

Continue reading "Potential ACOs Reluctant to Participate Under Proposed Rule" »

May 16, 2011

A Route to Quality Medicare Reform - Insight by CMS' Donald Berwick

It is often instructive to review the thinking of health care decision-makers as a tool to acquire insight on the direction of health care policy. In this regard, Dr. Donald Berwick, the administrator of the Centers for Medicare & Medicaid Services ("CMS"), recently authored an Op-Ed in the Wall Street Journal outlining his view of Medicare reform. In light of the fluidity of the debate on the direction of the federal health care program, we, at The Health Law Partners, have summarized the central principles in Dr. Berwick's piece. While Dr. Berwick's perspective is, by no means, devoid of the partisanship that has become so endemic in the health care debate, his article nonetheless demonstrates that the Administration intends to pursue the reform path enacted with the passage of the Patient Protection and Affordable Care Act ("PPACA") in 2010. It is noteworthy that, subsequent to the publication of this article, Dr. Berwick has acknowledged that the negative reception of the proposed ACO rules by the provider community inevitably will result in modifications to those rules.

Medicare reform may be a crucial building block toward a brighter economic future for the country because, among other benefits, successful reform could reduce the country's deficit and debt. The task, however, requires balancing the growing costs of Medicare with the enormous financial burden medical costs impose on families. A plan proposed by Republicans in Congress would shift the costs of healthcare to seniors and the disabled. The plan would eliminate guaranteed Medicare benefits, limit the choice of doctors and hospitals, and burden the average senior with $6,400 of insurance costs. Although Medicare spending might be reduced as a result, the overall cost of healthcare would continue to climb under this plan.

In the alternative, the Medicare system could follow the example set by other fields (e.g., the computer industry) and focus on lowering costs and improving efficiency. The groundwork for such an approach was laid out by the PPACA. Up to $1 billion will be invested by the Partnership for Patients to aid healthcare providers in improving the safety of care. This partnership will not only elevate the quality of health care delivery, but will reduce Medicare costs by an estimated $50 million. In another effort, CMS recently introduced a Proposed Rule for Accountable Care Organizations ("ACOs"). Under this rule, ACOs will coordinate patient care and facilitate better communication among providers to reduce duplicate tests and procedures which should result in decreased healthcare costs. According to Dr. Berwick, improving the quality of healthcare may prove to be the best route to successful Medicare reform and a brighter economic future for the country.

Continue reading "A Route to Quality Medicare Reform - Insight by CMS' Donald Berwick" »

May 3, 2011

ASA Posts FAQs on Accountable Care Organizations (ACOs)


In an effort to better educate the anesthesia community with regard to the impact of Accountable Care Organizations ("ACOs") on the specialty, the ASA Ad Hoc Task Force on ACOs has been carefully analyzing the March 31, 2011 ACO proposed regulations. As a preliminary step, at the end of April 2011, the ASA released 21 FAQs relative to ACOs. The ASA also plans to continually update the FAQs as new information emerges. The ASA FAQs can be accessed here.

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April 1, 2011

The Highly Anticipated ACO Guidance Has Been Issued!

On Thursday, March 31, 2011, the Centers for Medicare & Medicaid Services ("CMS") provided the health care community with some much needed guidance by publishing its Proposed Rule regarding the Medicare Shared Savings Program (the "Shared Savings Program") and its Accountable Care Organizations ("ACOs"). There is a sixty (60) day public comment period with respect to the Proposed Rule and CMS has encouraged members of the public, including physicians, to submit comments for consideration while the final regulations are being developed.

Within its almost 500 pages of text, the Proposed Rule sets forth an abundance of specific requirements that the ACOs will likely need to satisfy. In addition, the Proposed Rule provides further information regarding the payments that ACOs will receive from CMS. Notably, the Proposed Rule would not only allow ACOs to receive a share of the cost-savings that it generates based upon a benchmark set by CMS but would also require ACOs, at least eventually, to accept downside risk by requiring the ACOs to repay Medicare expenditures above the CMS benchmarks.

It is also important to note that the Proposed Rule was only one of several helpful publications simultaneously issued by Federal agencies, including the U.S. Department of Health and Human Services Office of Inspector General, the Federal Trade Commission, the Department of Justice and the Internal Revenue Service, in a coordinated effort to address barriers and resolve ambiguities with respect to the operation of the Shared Savings Program under health care fraud and abuse, anti-trust and tax exempt laws.

Additional information regarding each of these developments and the Proposed Rule itself can be found at http://www.cms.gov/sharedsavingsprogram/.

Continue reading "The Highly Anticipated ACO Guidance Has Been Issued! " »

March 31, 2011

ACO Proposed Regulations Issued

Today, CMS issued the long-awaited proposed regulations for accountable care organizations (ACOs). The regulations may be found here.

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March 15, 2011

ACO Regulations May Finally Be Near

Since the signing of the Patient Protection and Affordable Care Act (PPACA) last year, there has been considerable attention and interest within the industry towards accountable care organizations (ACOs). Accompanying this focus has been a series of questions regarding the compositional requirements, as well as the operational and structural opportunities to be afforded to (and limitations to be imposed upon) ACOs. Fortunately, for the myriad of hospital systems and other providers that are developing their clinical integration strategies, meaningful guidance may soon be forthcoming. At a Congressional hearing on March 11, Secretary Sebelius announced that the long-awaited ACO regulations are expected to be released within the next two weeks and that these regulations were designed to encourage a wide variety of healthcare collaborations. The Health Law Attorney Blog has been intently following ACO developments. Please check back for an update on the content of the to-be-released ACO regulations and the anticipated implications of these rules for the ever-evolving healthcare landscape.

Continue reading "ACO Regulations May Finally Be Near" »

November 22, 2010

CMS Seeks Comments On New Standards For ACOs; AMA and Other Health Organizations Respond

The Centers for Medicare & Medicaid Services (CMS) has officially requested comments from the physician community regarding policies and standards for accountable care organizations (ACOs) participating in the Medicare program under the Shared Savings Program or in connection with the Center for Medicare and Medicaid Innovation (CMMI).

CMS's request focuses on three areas of interest: participation of solo and small practice providers in ACOs; attribution of beneficiaries to ACOs; and the assessment of performance, quality and efficiencies of ACOs. Below is a summary of the information CMS is seeking, but the full request and directions for submitting comments can be found here: http://tinyurl.com/2a29moo. Please note that the deadline for comments to be submitted to CMS is 5:00pm on December 3rd, 2010.

Solo and small practice providers. How can solo and small practice providers be ensured equal opportunity to participate in Shared Savings Plans created by the Medicare program? How can these providers be given sufficient access to capital needed to fund their efforts? Should CMS consider other payment models besides those currently available to Medicare providers?

Attribution of beneficiaries. CMS is seeking a seamless attribution process of beneficiaries to ACOs. What is the best process and timing for this: before the start of a performance period, in order to target care coordination strategies, or at the end of a performance period to ensure accountability?

ACO Assessment. How can CMS evaluate ACOs based on the patient-centered criteria required by the Affordable Care Act? What quality measures should the secretary of the U.S. Department of Health and Human Services use to determine performance in the Shared Savings Program?

In a letter from the American Hospital Association (AHA) to CMS dated November 17, 2010, the AHA outlined principles that it would like to see guide the agency's approach to implementing ACOs. It said the goal of ACOs must be "delivery reform that improves quality, efficiency and the patient experience through accountable care," and suggested that the need for Medicare program savings should not hinder this type of delivery reform. The AHA's position is that the ACO program should be "treated as a pilot initially so that mid-course corrections can be implemented to reflect what is learned." Importantly, the association encouraged CMS to "explore opportunities to extend similar arrangements to rural providers who are interested in adopting delivery reforms." The full text of the AHA's letter to CMS can be seen here: http://tinyurl.com/299xnqo.

The Premier healthcare alliance, based in Charlotte, NC, is also among the major healthcare organizations who have already submitted a letter with recommendations to CMS regarding ACOs. Premier's letter asks that the Medicare ACO program be "flexible enough to allow innovation, but rigid enough so that the initial ACOs in the program inspire confidence in the concept." Premier also encouraged CMS to recognize physician assistants, nurse practitioners and certified nurse specialists as clinical providers that are equally eligible for Medicare Shared Savings bonuses. Like the AHA, Premier believes that such non-physician practitioners "will be central in developing a strong primary care base, particularly in rural and shortage areas." Premier's letter can be found here in its entirety: http://tinyurl.com/2vd26of.

Finally, the American Medical Association (AMA) defined a robust set of guidelines for ACOs at the organization's semi-annual policy-making meeting. These principles, which happen to coincide with CMS's request for comments and recommendations, emphasize that ACOs must be physician-led to guarantee quality patient care, be patient-centered in their focus, ensure that physician and patient participation stays voluntary and enable independent physicians to participate. The latter is of particular concern to the AMA, as significant barriers must be addressed to guarantee that physicians in all practice sizes can be successful in the new ACO models. For solo and small practice physicians, these barriers include a lack of resources, existing antitrust rules and conflicting federal policies. The AMA urges CMS to keep quality performance standards consistent with AMA policy and to allow ACOs to use different payment models. A complete list of all 13 principles of the AMA's new policy regarding accountable care organizations can be found here: http://tinyurl.com/2aamuyz.

Please continue to visit www.thehlp.com for further ACO-related developments and, in particular, view the resources at our ACO page.

Continue reading "CMS Seeks Comments On New Standards For ACOs; AMA and Other Health Organizations Respond" »

September 28, 2010

Update: FTC, CMS, and OIG October 5th Workshop on ACOs

Pursuant to our September 11, 2010 blog entry, the FTC is to hold a day-long workshop entitled "Workshop Regarding Accountable Care Organizations and Implications Regarding Antitrust, Physician Self-Referral, Anti-Kickback and Civil Monetary Penalty Laws." According to the workshop's website, those who are unable to attend the Baltimore workshop may listen in via webcast. Registration is not required for the webcast. HLP will be listening in on the webcast and will provide our readers with our summary of the workshop. Please stay tuned for more updates!

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