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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.


For more information regarding ACOs, please contact Carey F. Kalmowitz, Esq. or Esq. at (248) 996-8510 or (212) 734-0128 or visit the HLP website.

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