Medicare Shared Savings Program

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Healthcare Legal News: Volume 5, Number 1

CMS ANNOUNCES NEW RULES THAT MAKE OWNER DOCTORS LIABLE FOR ALL PRACTICE MEDICARE DEBTS - Even after they leave the Practice. CMS announced its final rules on "Medicare Provider Oversight" on December 3, 2014....more

Summary Chart Of Proposed Amendments To 42 C.F.R. Part 425 Governing The Medicare Shared Savings Program

Mintz Levin has prepared a chart of the proposed amendments to 42 C.F.R. Part 425 governing the Medicare Shared Savings Program. This chart provides a summary of each proposed amendment and its potential impact....more

IRS Interim Guidance Creates New Category of Permissible Arrangements - Public Comments Due January 22, 2015

On October 24, 2014, the IRS issued Announcement 2014-67, which “amplifies” Rev. Proc. 97-13 regarding certain management contracts that do not result in private business use. Prior to this Announcement, Rev. Proc. 97-13...more

IRS Interim Guidance Creates New Category of Permissible Arrangements

On October 24, 2014, the IRS issued Announcement 2014-67, which “amplifies” Rev. Proc. 97-13 regarding certain management contracts that do not result in private business use. Prior to this Announcement, Rev. Proc. 97-13...more

A Quick Look at Healthcare Issues Expected to Make News in 2015

As we look into our crystal balls, we do not expect a lot of new issues in 2015. Rather, we believe that most of the significant issues will be a continuation of issues that arose in 2014 or earlier. ...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

2014 – The Health Law Year in Review

Each year brings significant changes and challenges in the laws governing the health care industry, and 2014 proved to be no exception. What the year may have lacked in the high drama that accompanies comprehensive health...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

Department Of Health And Human Services Issues Proposed New Rules Implicating The Use Of Electronic Health Records And Patient...

On December 8, 2014, the U.S. Department of Health and Human Services (“HHS”) issued a proposed rule related to changes to the Medicare Shared Savings Program. These revisions promote the use of electronic health records by...more

Touching Up that Old Two Step: CMS Proposes Revisions to its Beneficiary Assignment Methodology

On Dec. 1, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses...more

CMS Proposes Financial Revisions to MSSP to Encourage Continued and Expanded Participation

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

CMS ACO Proposed Rule to Extend One-Sided Risk Track While Incentivizing Performance-Based Risk

On December 1, 2014, the U.S. Centers for Medicare & Medicaid Services (CMS) released a 429-page Proposed Rule setting forth significant changes that will affect the evolution of the Medicare Shared Savings Program (MSSP) and...more

CMS Proposes Changes to the Medicare Shared Savings Program

The Centers for Medicare and Medicaid Services (CMS) recently published a proposed rule (Proposed Rule) that would revise regulations governing accountable care organizations (ACOs) that participate in the Medicare Shared...more

Health Reform + Related Health Policy News - December 2014, Issue 1

In This Issue: - Top News ..Congress Passes Omnibus Spending Package ..HRSA Cancels Plan for 340B ‘Mega Reg’; Congress Weighs Options ..Supreme Court to Hear Challenge to ACA...more

Beneficiary Assignment in the Proposed Revised Medicare Shared Savings Program Regulations

This post addresses the changes that the rule would make to how CMS assigns beneficiaries to an ACO participating in the MSSP. The Proposed Rule places a renewed emphasis on primary care for beneficiary assignment. Section...more

CMS Proposes Sharing More Data With ACOs Participating in the Medicare Shared Savings Program

CMS may be ready to ramp up the data it is willing to share with Accountable Care Organizations (“ACOs”) that participate in the Medicare Shared Savings Program (“MSSP”). CMS explained in the November 2011 final rule...more

Changing Basic Rules of the Game: CMS Proposed Rule Relating to ACO Governance and Contracting

The Centers for Medicare and Medicaid Services released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory expands upon our initial...more

MSSP Proposed Rule Seeks to Enhance ACO Transparency and Patient Engagement

Under the Medicare Shared Savings Program (“MSSP”) ACO proposed rule, CMS has proposed additional program requirements, beneficiary protections and participation agreement procedures to enhance ACO transparency and improve...more

CMS Releases New Proposal to Improve Accountable Care Organizations

The Centers for Medicare and Medicaid Services (CMS) recently released a proposed rule aimed at revitalizing accountable care organizations (ACOs) under the Medicare Shared Savings Program (MSSP). Given the low level of ACOs...more

Keeping Track of the Tracks: Proposed ACO Regulations Alter MSSP Financial Models

Last week, the Centers for Medicare and Medicaid Services (“CMS”) released a new proposed rule for Accountable Care Organizations (ACOs) participating in the Medicare Shared Savings Program (MSSP). This advisory focuses on...more

CMS Invites Comment on Availability of Waivers for ACOs That Particularly Affect Post-Acute Care

Solutions and opportunities may be on the horizon for post-acute providers (“PAPs”) and hospitals participating (or thinking of participating) in ACOs that have reservations about taking on additional downside cost risk...more

CMS’s Proposed Changes to the MSSP Aim to Grow Two-Sided Risk Models and Modify Processes for Evaluating and Facilitating Care...

The Centers for Medicare & Medicaid Services (CMS) has published long-awaited changes to the Medicare Shared Savings Program (MSSP). The official version of the proposed rule (the Proposed Rule), released December 8th, 2014,...more

Health Care Reform Implementation Update

We are now more than two weeks into the Affordable Care Act (ACA’s) second open enrollment period, and 765,000 individuals have obtained coverage through HealthCare.gov. On Capitol Hill, House lawmakers filed a lawsuit...more

Medicare Shared Savings Program: CMS Announces Proposed Changes Affecting All ACOs

On December 1, 2014, the Centers for Medicare & Medicaid Services (“CMS”) issued a proposed rule that would implement changes to the Medicare Shared Savings Program (“MSSP”). We summarized the original rules, finalized on...more

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