Medicare Shared Savings Program

News & Analysis as of

Summary of Major Provisions in the Proposed 2017 Physician Fee Schedule

The proposed Physician Fee Schedule for 2017 (PFS) includes several changes covering a litany of topics spanning from telehealth services to expanding the Diabetes Prevention Program Model. The following is a high-level...more

CMS Issues Medicare Physician Fee Schedule Proposed Rule

On July 7, 2016, CMS issued a proposed rule that updates payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2017 (Proposed...more

IRS Denial of Accountable Care Organizations Raises More Questions Than It Answers

In a recent ruling, PLR 201615022, the IRS denied tax exemption to an accountable care organization on the basis that the organization was conferring private benefit on its participating physicians by negotiating shared...more

IRS Denies Exempt Status for Non-MSSP Accountable Care Organizations

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

CMS Issues Final Rule on ACOs Participating in the Medicare Shared Savings Program

The Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (the “Final Rule”) for accountable care organizations (“ACOs”) participating in the Medicare Shared Savings Program (“MSSP”) on June 6, 2016. In the...more

New ACO Rule: Continued CMS Efforts to Promote Program Participation

On June 6, 2016, the Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (the “Final Rule”) for accountable care organizations (“ACOs”) participating in the Medicare Shared Savings Program (“MSSP”). The Final...more

CMS Finalizes Changes to Medicare Shared Savings Program/ACO Benchmark Rebasing Rules

CMS has published a final rule that revises the methodology CMS uses to measure the performance of accountable care organizations (ACOs) in the Medicare Shared Savings Program. According to CMS, the changes are intended to...more

OIG Releases Mid-Year Update to its FY 2016 Work Plan

The HHS OIG has updated its FY 2016 Work Plan to reflect new and/or completed items since initial release of the FY 2016 Work Plan in November 2015. For instance, the mid-year update indicates that the OIG plans to conduct...more

APMs, MIPS, and the Final MSSP Rule - The Journey from Volume to Value-Based Reimbursement Continues

Since the Affordable Care Act was enacted, many providers have been shifting away from traditional fee-for-service, volume-based reimbursement models to payment mechanisms that take a data-driven approach to managing patients...more

New Rules for ACOs in the MSSP

CMS issued a final rule, published in the Federal Register on Friday, June 10, 2016, updating how the performance of ACOs participating in the Medicare Shared Savings Program (MSSP) is measured and compensated. This rule is...more

CMS Releases Final Shared Savings Program Rule

On June 6, 2016, CMS issued a final rule (Final Rule) establishing a phased approach for incorporating regional FFS expenditures into calculations for resetting, adjusting, and updating Accountable Care Organizations’ (ACOs’)...more

Medicare Makes Changes to the Shared Savings Program to Strengthen Incentives for ACO Care Coordination

On June 6th, the Centers for Medicare & Medicaid Services (CMS) released a final rule shifting how Medicare pays Accountable Care Organizations (ACO) in the Medicare Shared Savings Program. CMS said the final rule aims to...more

CMS Redefines Alternative Payment Models and Offers Option for Merit-Based Incentive Payment System in New Proposed Rule

The Medicare Access and CHIP Reauthorization Act (MACRA) is expected to drastically change how physicians are paid by the Centers for Medicare and Medicaid Services (CMS). Under the proposed rule, physicians will be given the...more

American Hospital Association Urges IRS To Affirm that Tax-Exempt Hospitals Can Participate in Non-Medicare ACOs

The American Hospital Association (AHA) has written to John Koskinen, Commissioner of the Internal Revenue Service (IRS), and Mark Mazur, Assistant Secretary for Tax Policy at the Treasury Department, raising concerns about...more

Accountable Care, Non-Profit Status and the Dangerous Ripple Effect it May Cause

On April 8, 2016, the Internal Revenue Service (IRS) released Private Letter Ruling (PLR) 201615022, which denied tax-exempt 501(c)(3) status to a commercial accountable care organization (ACO). This ruling marks the first...more

8 tips for engaging ACO boards to meet requirements in the Final Waivers

In the Final Waivers for the Medicare Shared Savings Program (MSSP) issued by the CMS and the OIG, the regulators modified the requirements for the ACO governing body stating that it must provide “the basis for the...more

Medicare Rolls Out Proposed Rule Altering Physician Payment Model

Currently, Medicare measures the value and quality of care provided by doctors and other clinicians through a patchwork of programs. Some clinicians are part of Alternative Payment Models such as the Accountable Care...more

IRS Ruling Sounds Alarm over Tax-Exempt Status of Nonprofit ACOs Operating outside of the Medicare Shared Savings Program

On April 8, 2016, the IRS released private letter ruling 201615022 denying tax-exempt section 501(c)(3) status to a nonprofit accountable care organization (“ACO”) that did not participate in the Medicare Shared Savings...more

IRS Denial of Section 501(c)(3) Status for a Commercial ACO

The IRS recently released a ruling, Private Letter Ruling (“PLR”) 201615022, denying Section 501(c)(3) tax-exempt status to a “commercial” accountable care organization (“ACO”). This is the IRS’ first published guidance...more

CMS Ahead of Schedule in Push for Medicare Alternative Payment Models

CMS has announced that has reached its goal of tying 30% of Medicare payments to alternative payment models that reward quality of care rather than volume of service — 11 months ahead of the target CMS set last year....more

CMS Issues a New Medicare Shared Savings Program Proposed Rule and Aims to Encourage Existing Accountable Care Organizations to...

On February 3, 2016, the Centers for Medicare and Medicaid Services (“CMS”) issued a new proposed rule that makes a number of revisions to the Medicare Shared Savings Program (“MSSP”). Several of the proposed changes create...more

CMS Schedules Calls on Medicare ACO Application Process (April 5 and 19)

CMS is holding two calls in April on the Medicare Shared Savings Program/Accountable Care Organization application process. The first call, scheduled for April 5, will focus on preparing for the Shared Savings Program...more

CMS Listening Session on Proposed Changes to Medicare Shared Savings Program Rules (March 3)

On March 3, CMS is hosting a “listening session” to receive feedback on proposed changes to the Medicare Shared Savings Program benchmarking methodology published on February 3, 2016. In particular, CMS invites comments on...more

Health Update - February 2016

Better Late Than Never: CMS Provides Much-Needed Clarity on the 60-Day Overpayment Refund Requirements - On February 12, 2016, the Centers for Medicare & Medicaid Services (CMS) issued the long-awaited final rule (Final...more

Proposed Changes to Methodology to Update ACO Benchmarks

The Medicare Shared Savings Program provides financial rewards to Accountable Care Organizations (ACO’s) that successfully manage overall health care costs for a defined population of beneficiaries while meeting quality of...more

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