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By Garfunkel * Wild PC

As ME-P readers may know, the much anticipated proposed federal regulations on accountable care organizations (ACOs) were published on March 31, 2011.

The ACA

Under the Affordable Care Act, ACOs were created for the purpose of delivering seamless, high quality care to traditional fee-for-service Medicare beneficiaries while reducing the cost of care to those beneficiaries.  If successful, ACOs would receive a portion of the shared savings.  The proposed regulations detail how these ACOs will work.

Work Group

The Garfunkel Wild ACO workgroup is analyzing these proposed regulations, and shortly we will provide a review with pragmatic points to consider.

In sum, all ACOs that wish to participate in Medicare Shared Savings Program will enter into 3-year agreements with the Department of Health and Human Services, but CMS is proposing a two track approach.  Those ACOS that opt for the first track will have the opportunity to share in actual savings at no risk for the first two years.  In year three, the ACO will have the ability to receive additional savings but also will be at financial risk if certain benchmarks are not met.  ACOs that elect the second track have the same ability to share in savings but are financially at risk from day one.

CMS and OIG Regulations

Also published with the proposed CMS regulations are proposed regulations from the Office of Inspector General that address the waiver of the application to ACOs of federal fraud and abuse laws; a solicitation for comments from the Internal Revenue Service regarding the need for tax guidance for tax-exempt organizations, and perhaps the most important, a statement from the Federal Trade Commission and Department of Justice that proposes a safety zone that will protect from antitrust enforcement ACOs and other “collaborative care organizations” that serve patients with commercial insurance, not just Medicare beneficiaries.

Assessment

There are a lot of moving parts, and nothing yet is final.  The comment period on these proposed regulations ends June 6, 2011.

Link: http://www.garfunkelwild.com

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Filed under: "Doctors Only", Alerts Sign-Up, Health Law & Policy, Practice Management | Tagged: ACO, ACO Federal Regulations, Affordable Care Act., CMS, DHHS, FTC, Garfunkel Wild, IRS, OIG | 10 Comments »