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…
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…
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…
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…
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…
Today, CMS issued the long-awaited proposed regulations for accountable care organizations (ACOs). The regulations may be found here. For more information, please contact the Health Law Partners at (248) 996-8510, (212) 734-0128 or (770) 804-6475 or visit the ACO specialty page on the HLP website.
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…
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…
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…
The Federal Trade Commission (“FTC”), Centers for Medicare and Medicaid Services (“CMS”), and Department of Health and Human Services Office of Inspector General (“OIG”) have announced their plans to co-host an October 5th workshop on accountable care organizations (“ACOs”). According to a September 8th News Release, the workshop is intended…