Accountable Care Organizations

Subscribe to Accountable Care Organizations RSS Feed

ACO Regulation Review and Application Preparation Webinar

Join Squire Sanders and Strategic Health Care this Friday, April 8 at 11 a.m. EDT for a national webinar, “ACO Regulation Review and Application Preparation.” Squire Sanders partners Peter A. Pavarini and John M. Kirsner will discuss legal considerations relevant to the proposed Accountable Care Organization (ACO) regulations issued by the Centers for Medicare & Medicaid Services … Continue Reading

When it Comes to the Waiver Regulations, Comment Early!

I agree with my colleagues that CMS appears to be looking to the industry to guide them on waiver development, as well as other details of the Medicare Shared Savings Program. CMS intends to grant waivers that would apply uniformly to all ACOs, ACO participants and ACO providers/suppliers participating in the Medicare Shared Savings Program. … Continue Reading

Introducing Risk Through a Shared Savings Program: The Two-Sided Model – A Carrot and Stick Approach

The Accountable Care Act permits the Secretary of HHS to implement partial capitation models or any other payment model the Secretary determines will improve quality and efficiency. The Proposed Rule states that the Secretary will test partial capitation models in the Innovation Center. Pursuant to the “other payment model” authority, however, the Proposed Rule would … Continue Reading

Proposed ACO Waiver Regulations: Not Far Enough? An OIG Challenge During My Presentation at Friday's AHLA Medicare and Medicaid Institute

Does anyone else feel that the proposed waiver regulations don’t go far enough? Do you think they allow providers to engage in flexible arrangements that deliver value to the government? The key is how the government has limited the waiver proposals mostly only to the shared savings distributions. That seems too narrow, although I think … Continue Reading

Antitrust Considerations from the Recently Released ACO Proposed Regulations

The Federal Trade Commission and Department of Justice (the “Agencies”) recently released Proposed Statement of Antitrust Enforcement Policy Regarding ACOs, which contains several points of interest: Rule of Reason Treatment. The Agencies will provide rule of reason treatment to an ACO if, in the commercial market, the ACO uses the same governance and leadership structure and … Continue Reading

ACO 101 – Unicorns No More

By Daniel J. Vukelich, President, Association of Medical Device Reprocessors I’ve been thinking about Robert Pear’s analogy, as he wrote in today’s New York Times that: Until now, accountable care organizations were like unicorns, creatures that flourished in the imagination but proved persistently elusive in the natural world. The rules define the new entity as a … Continue Reading

ACO Rules – Initial Observations

The proposed CMS rules for accountable care organizations have only been out a few hours and even the speediest readers are still plowing through them, but a few initial observations are in order: CMS is admitting it needs more than the usual amount of public comment to craft final rules. Perhaps this was intentional but … Continue Reading

FTC/DOJ Release Joint Guidance on ACOs

Several important antitrust points of interest in the hot-off-the-presses ACO regulations issued today: The Department of Justice and the Federal Trade Commission have a new challenge – figuring rules of the road as joint administrators of the ACO antitrust review process, acting through a newly formed joint working committee. The agencies will either have to … Continue Reading

Pediatric ACOs – Helping to Balance Ohio's Budget

On March 15, Ohio Governor John Kasich announced his proposal to balance Ohio’s budget (the Blue Book).   Because the Ohio budget is in large part reserved for Medicaid, health care changes play a significant role in the new budget plan. Governor Kasich’s budget proposal included establishing pediatric accountable care organizations (Pediatric ACOs).  The following discussion outlines the … Continue Reading

Patient-Centered Care and Accountable Care Organizations in an Era of Health Care Reform

At the 2011 University of Miami Global Business Forum, a panel was convened to discuss accountable care organizations (ACOs).  This panel broke new ground in answering how health care reform and market forces will create patient-centered care and ACOs.   ACO is defined by the Centers for Medicare and Medicaid Services (CMS), as “an organization of health care providers … Continue Reading