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CMS Launches Next Generation ACO

The Centers for Medicare and Medicaid Services (“CMS”) has released information about a new accountable care organization (“ACO”) model, called the Next Generation ACO. According to CMS, “the Next Generation ACO Model offers...more

Late Notice of Claim Costs Kentucky Hospital $10 Million

A federal court in Kentucky ruled on March 17 that Ashland Hospital had forfeited $10 million of insurance coverage because it was late in notifying its insurance company of the claim....more

CMS Unveils New ACO Model

On March 10, 2015, CMS announced a new accountable care organization (ACO) model designed to increase both risk-sharing by participating providers and potential shared savings. Parties interested in participating in this...more

CMS Announces New "Next Generation" ACO Model; Schedules 3/17 Call

On March 10, 2015, CMS announced the Next Generation Accountable Care Organization (ACO) Model, its latest Affordable Care Act (ACA) innovation initiative intended to promote Medicare quality improvement and care...more

Next Generation ACOs: CMMI Doubles Down on the Two-Sided Risk ACO Model

While one part of the Affordable Care Act, exchange subsidies, hangs in the balance with the Supreme Court’s upcoming decision in King v Burwell, CMS is moving forward aggressively with the evolution of a less controversial...more

Letter of Intent to Participate in Next Generation ACO Model is Due May 1, 2015

In a press release dated March 10, 2015, the CMS Innovation Center announced what it called the Next Generation ACO Model. For health care providers, this opens a new opportunity for developing an integrated model of care. ...more

CMS Posts Deadlines for 2016 Medicare Shared Savings Program Application Cycle; Schedules Informational Calls

CMS is gearing up for the program year 2016 Medicare Shared Savings Program, under which physicians, hospitals, and certain other types of providers and suppliers may form Accountable Care Organizations (ACOs) to provide...more

Medicare ACO v.3.0—More Risk, More Money?

The Centers for Medicare and Medicaid (CMS) announced on March 10, 2015 that it is adding a new Accountable Care Organization (ACO) model to its cadre of innovative models. Titled the “Next Generation ACO Model,” CMS’ new ACO...more

Obama Administration Announces “Next Generation ACOs”

In a highly anticipated announcement on Tuesday, March 10, the Centers for Medicare and Medicaid Services (CMS) released details for a new Accountable Care Organization (ACO) program called the Next Generation ACO (NGACO). ...more

Reported Compliance Problems: The Six Stages of Corporate Grief

Last week, I had the honor of participating in a panel discussion about how health care entities deal with reported compliance concerns at the ABA’s 16th Annual Conference on Emerging Issues in Healthcare Law. The panel was...more

HHS Announces Next Generation ACO Model of Payment

On Tuesday, March 10, 2015, the U.S. Department of Health and Human Services ("HHS") announced the introduction of the Next Generation Accountable Care Organization ("ACO") Model of payment and care delivery. ACOs...more

Will the ACO Proposed Rule Save the Shared Savings Program?

In 2011, CMS implemented the Accountable Care Organization (“ACO”) Shared Savings Program, which aims to promote increased savings for the Medicare program, improve health care quality, and create a more efficient and...more

Medical Staff By-laws are Contracts? Minnesota Supreme Court Says “Yes”

That sound you just heard was the simultaneous gasp of hospital boards of directors throughout the state of Minnesota. In Medical Staff of Avera Marshall Regional Medical Center v. Avera Marshall, Minnesota’s highest court...more

IRS Issues Private Letter Ruling on Treatment of Managed Professional Corporations

The Internal Revenue Service (“IRS”) recently published a private letter ruling (“PLR”) that permits a practice management corporation to include two managed professional corporations as members of the management...more

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

Premium Reimbursement Arrangements Get Relief - More ACA Transition Relief—This Time for Small Employers and S-Corps

The IRS issued guidance on Feb. 18, 2015, providing temporary relief until June 30, 2015, from steep penalties for small employers and S-corps that have continued to use premium reimbursement arrangements to provide health...more

IRS Ruling Permits Inclusion of “Friendly PCs” in Consolidated Federal Income Tax Returns

On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the...more

Great Tax Planning Opportunity

Undoubtedly, right before the end of the year, you were inundated with information about steps you could take as part of the year-end tax planning for your practice. While the end of the year does offer great tax planning...more

End of 2014 Tax Law Changes

ABLE Accounts: A new law titled “Achieving a Better Life Experience” (ABLE) allows the establishment of tax-free accounts that can be used to save for disability-related expenses. ABLE accounts can be created by individuals...more

Novartis and Qualcomm Form Digital Health Investment Company

Novartis Pharmaceuticals has announced it has formed a joint investment company with Qualcomm Ventures, the venture investment group of Qualcomm....more

New IRS Ruling Benefits Investor-Owned Hospitals

Last month, the Internal Revenue Service (IRS) issued a private letter ruling providing a tax benefit to hospitals that own physician practices. The ruling should be of particular interest to hospitals with physician...more

CMS Proposes Changes to the Medicare Shared Savings Program MSSP

On December 1, 2014, CMS published its proposed changes and updates to the Medicare Shared Savings Program (MSSP) for Accountable Care Organizations (ACOs). Comments are due by February 6, 2015. Below is a summary of the...more

CMS’ Proposed Regulations Include Significant Antitrust Implications For Entities Interested In Forming ACOs

The Centers for Medicare & Medicaid Services (CMS) released proposed regulations to clarify and build on current regulatory requirements for Accountable Care Organizations (ACOs) that participate in the Medicare Shared...more

IRS Private Letter Ruling Addressing Captive Professional Corporations Could Result in Significant “Consolidated” Tax Savings

On December 19, 2014, the Internal Revenue Service published PLR 201451009, favorably ruling that a for-profit management company could include its captive professional corporation as a member of its consolidated group for...more

CMS Announces Latest Group Of MSSP ACOs And May Allow ACOs To Remain As “Upside-Risk Only” Longer

December has been a busy month for CMS with respect to the Medicare Shared Savings Program (“MSSP”). Last week CMS announced that eighty-nine (89) more ACOs would begin participating in the MSSP starting in 2015, bringing the...more

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