The Centers for Medicare and Medicaid Services (CMS) and HHS Office of the Inspector General posted proposed regulations and requests for comment to further implementation of the Medicare Shared Savings Program created by the Patient Protection and Affordable Care Act. In addition, the Department of Justice and the Federal Trade Commission published guidance regarding the antitrust implications of accountable care organizations. Health care lawyers and other related professionals will be spending some quality time with this new guidance, to ensure providers are properly structuring accountable care organizations (ACOs). Finally, the Internal Revenue service posted a request for comment, to address potential issues facing exempt organization participating in ACOs.
Squire Sanders is pleased to announce that we have started a new blog to discuss the developing ACO regulations, so stop by our new blog and give us your thoughts. These are proposed regulations, so the various agencies are open to comments on their proposals before they finalize the rules. Our goal is to create a forum on our new blog to discuss ideas and possible comments to the agencies as we work our way through the regulations and the new ACO environment.