On August 30, 2022, the Centers for Medicare & Medicaid Services (CMS) announced that the Medicare Shared Savings Program (MSSP) had saved the Medicare program $1.66 billion in 2021 as compared to spending targets, while...more
The Centers for Medicare and Medicaid Services (CMS), as part of 2023 Physician Fee Schedule proposed rule, has proposed significant revisions to the Medicare Shared Savings Program (MSSP). The revisions to the MSSP in the...more
The Centers for Medicare and Medicaid Services (CMS) issued a final rule (the Rule) on December 21, 2018, which reshapes the Medicare Shared Savings Program (MSSP). Termed “Pathways to Success,” the Rule, among other...more
On August 9, 2018, CMS introduced a proposed rule that would substantially overhaul the Medicare Shared Savings Program (MSSP), requiring Accountable Care Organizations (ACOs) that participate in the MSSP to accept some...more
Despite some initial difficulty in gaining momentum, the use of value-based payment methodologies will likely increase across all provider niches. This change is partly a function of cost savings driven by margin compression...more
On December 20, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule (the Final Rule) which includes three new mandatory episode-based payment programs for cardiac care, as well as the expansion of the...more
In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”)....more
7/15/2016
/ 501(c)(3) ,
ACOs ,
Affordable Care Act ,
Exempt Organizations ,
Health Care Providers ,
Hospitals ,
IRS ,
Medicare Shared Savings Program ,
Physicians ,
Private Letter Rulings ,
Third-Party ,
Unrelated Business Income Tax
The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule modifying the Medicare Shared Savings Program (MSSP) regulations (the “Rule”). Among other changes, the Rule proposes (a) to modify the...more
Accountable Care Organizations (ACOs) can share costs of telehealth and remote patient monitoring services among their hospitals, providers/suppliers, and other ACO participants, according to federal regulations under the...more
11/3/2015
/ ACOs ,
Alternative Payment Models (APM) ,
Centers for Medicare & Medicaid Services (CMS) ,
Fee-for-Service ,
Fraud and Abuse ,
Health Care Providers ,
Health Information Technologies ,
Healthcare ,
Healthcare Reform ,
Hospitals ,
Medicare ,
Medicare Shared Savings Program ,
OIG ,
Suppliers ,
Telehealth ,
Telemedicine ,
Value-Based Purchasing ,
Waivers
The Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) of the Department of Health and Human Services just issued a final rule setting forth waivers of specified fraud and abuse laws...more
11/2/2015
/ ACOs ,
Centers for Medicare & Medicaid Services (CMS) ,
Final Rules ,
Fraud and Abuse ,
Gainsharing ,
Healthcare ,
Home Health Care ,
Medicare ,
Medicare Shared Savings Program ,
OIG ,
Required Documentation ,
Waivers
The Centers for Medicare and Medicaid Services (CMS) released, on August 25, 2015, the quality and financial performance results for Medicare Accountable Care Organizations for 2014. CMS touted that Medicare ACOs continued to...more
9/10/2015
/ ACOs ,
Alternative Payment Models (APM) ,
Bundled Payments ,
Centers for Medicare & Medicaid Services (CMS) ,
Electronic Medical Records ,
Health Care Providers ,
Healthcare Costs ,
Medicare ,
Medicare Shared Savings Program ,
Physician Medicare Reimbursements ,
Quality of Care Standards
This is the fifth post in Health Care Law Today’s series on the final rule.
The final Medicare Shared Savings Program (“MSSP”) rule released on June 4, 2015, contains a number of modifications to the financial...more
This is the third post in Health Care Law Today’s series on the final rule. This post addresses changes to sharing of beneficiary identifiable data.
In its December 8, 2014 proposed rule revising the Medicare Shared...more
This is the second post in Health Care Law Today’s series on the final rule. This post addresses Eligibility Requirements, and the Application and the Renewal Process.
ACO Eligibility Requirements -
Under the...more
6/24/2015
/ ACO Participant Agreements ,
ACOs ,
Applications ,
Board of Directors ,
Centers for Medicare & Medicaid Services (CMS) ,
Compliance ,
Corporate Governance ,
Duty of Loyalty ,
Eligibility ,
Fiduciary Duty ,
Final Rules ,
Governance Standards ,
Health Care Providers ,
Healthcare ,
Medicaid ,
Medicare ,
Medicare Shared Savings Program ,
Renewal Options ,
Suppliers ,
Transparency
This is the first post in Health Care Law Today’s Series on the final rule.
The Centers for Medicare and Medicaid Services (“CMS”) released a final rule, on June 4, 2015, addressing changes to its Medicare Shared Savings...more
CMS announced a new ACO payment initiative on March 10, 2015, the Next Generation ACO Model, designed for entities experienced in coordinating care for populations of patients. The announcement reflects CMS’ commitment to...more
Many critics have suggested that the November 11, 2011 final rule establishing the MSSP created a financial model that over time would not be sustainable. ACOs viewed the requirement to take risk after the initial three years...more
The Centers for Medicare and Medicaid Services released, on December 1, 2014, a proposed rule to revise the Medicare Shared Savings Program (“MSSP”) Accountable Care Organization (“ACO”) Regulations. The proposed rule is...more
The American Hospital Association (AHA) submitted a letter to the Centers for Medicare and Medicaid Services (CMS) on April 17, 2014, recommending modifications to the Medicare Shared Savings Program (MSSP) and the Pioneer...more
On January 30, 2014, CMS released results on the Medicare Shared Savings Program (“MSSP”) and the Pioneer Accountable Care Organization Program (“Pioneer ACO Program”) for 2012, the initial performance year of each program....more
On July 16, 2013, CMS announced results from the first performance year of the Pioneer Accountable Care Organization (ACO) Model. In the release, CMS reported that the Pioneer ACO participants held Medicare cost increases...more