News & Analysis as of

Medicare Internal Revenue Service Medicare Shared Savings Program

Sheppard Mullin Richter & Hampton LLP

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

McDermott Will & Emery

CMS Issues Final ACO Rules: Key Legal Implications for Hospital & Health System ACOs

McDermott Will & Emery on

On June 4, 2015, the Centers for Medicare & Medicaid Services (CMS) released a final rule (Final Rule) containing changes to its Medicare Shared Savings Program (MSSP). Some of the changes codify informal guidance that the...more

Akerman LLP - Health Law Rx

ACO Participation By Tax-Exempt Healthcare Organizations – Is Tax-Exempt Financing at Stake?

Does A Tax-Exempt Healthcare Organization’s Participation in an Accountable Care Organization (ACO) Adversely Affect Its Tax-Exempt Financing? IRS Notice 2014-67 Provides Guidance....more

Cozen O'Connor

IRS Releases Guidance on Private Business Use, and ACOs and Management Contracts

Cozen O'Connor on

On October 25, 2014, the Internal Revenue Service (the IRS) released Notice 2014-67 that provides interim guidance on (i) participation in the Medicare Shared Savings Program through an accountable care organization (ACO) and...more

McCarter & English, LLP

Notice 2014-67—Safe Harbors for ACOs and a New Management Contract Safe Harbor for Everyone

McCarter & English, LLP on

On Friday, Oct. 24, 2014, the Internal Revenue Service released interim guidance, Notice 2014-67, on whether a state or local government entity or an organization described in §501(c)(3) of the Internal Revenue Code of 1986,...more

Bracewell LLP

IRS Releases Private Business Use Guidelines for ACO Participants

Bracewell LLP on

On Friday, October 24, 2014, the Internal Revenue Service (IRS) released Notice 2014-67, providing guidance regarding the circumstances under which participation by a hospital in an Accountable Care Organization (ACO) will...more

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