On October 20, 2011, the Centers for Medicare & Medicaid Services (CMS) announced the Interim Final Regulations regarding the formation of accountable care organizations (ACO). As you may recall, these interim final regulations are the follow-up to the proposed regulations initially published by the government in the spring of this year. The final regulations take into account the over 1300 comments submitted to the Department before its June deadline. There have been several significant changes to various aspects of the ACO requirements. These include changes to the beneficiary assignment process, a reduction in the number of quality measures providers will be required to report, implementation of a rolling admissions process, and changes to the models of ACOs which will be implemented.

We recognize that these final regulations will spur much discussion within your organizations. The Healthcare team at Akerman stands ready to assist you as you navigate this new regulatory sea and perhaps begin the process of creating or joining an ACO. We have summarized these changes below.