Concurrently with the release of the final rule for accountable care organizations participating in the Medicare Shared Savings Program (“MSSP”), the Centers for Medicare and Medicaid Services (“CMS”) and the Department of Health and Human Services, Office of Inspector General (“OIG”) released an interim final rule with a comment period addressing waivers of certain fraud and abuse laws in connection with the MSSP.
The Federal Trade Commission (“FTC”) and the Department of Justice (“DOJ”) have also released a final “Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program.”  The antitrust policy is available on the websites of both the FTC and the DOJ.
As analysis and implications of these new rules become available, we will continue to serve as a free resource. Please join the discussion by offering your view, or if you’re interested in submitting an analysis, write me at  Also, journalists seeking expert sources on the implications of ACO and other health care reform rules should contact