The Center for Medicare and Medicaid Services (CMS) has published a 957-page final rule that confirms changes made to the Medicare Shared Savings Program (MSSP). This new rule will be expected to have a substantial impact on Accountable Care Organizations (ACOs) that rely on one-sided risk models, in so far…
March 2018 – Recent additions to the Medicare Shared Savings Program (“MSSP”), include several changes aimed to encourage Medicare beneficiaries to take a more proactive approach with their health care. By way of background, on March 23, 2010, Section 3022 of the Affordable Care Act added section 1899 (42 U.S.C.…
On March 6, 2017, House Republicans released the much-anticipated American Health Care Act (“AHCA”) bill that would effectively replace the Patient Protection and Affordable Care Act (the “ACA”), which is currently responsible for covering approximately 20 million individuals through a combination of health insurance offered through state-based and federally-run Exchanges…
The United States Department of Health and Human Services Office of Inspector General (“HHS-OIG”) has released its Work Plan for Fiscal Year 2016. This plan summarizes new and continuing areas of review and activities that HHS-OIG plans to pursue as well as describing its primary objectives. The newest additions to…
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…
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…
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…
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…
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…
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…