News & Analysis as of

Shared Savings Program

Bass, Berry & Sims PLC

More Losses than Gains? OIG Declines to Approve Certain Medicare Advantage Gainsharing Arrangements in Advisory Opinion 24-08

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On September 13, the U.S. Department of Health and Human Services Office of Inspector General (OIG) published Advisory Opinion 24-08, in which it declined to approve a proposal by a Medicare Advantage organization (MAO)...more

Arnall Golden Gregory LLP

Healthcare Authority Newsletter - July 2024 #1

News Briefs - Texas Federal Court Ruling Puts Noncompete Ban on Hold - A Texas federal court issued a preliminary injunction against the Federal Trade Commission's noncompete ban, which if implemented would allow existing...more

Greenbaum, Rowe, Smith & Davis LLP

HHS Finalizes Rule Establishing Significant Financial Penalties for Information Blocking by Healthcare Providers

On June 24, 2024, the U.S. Department of Health and Human Services (HHS) released a final rule establishing stringent financial penalties, referred to as “disincentives,” for healthcare providers found to have committed...more

Greenbaum, Rowe, Smith & Davis LLP

COVID-19 And Medicare Alternate Payment Programs

Insurance payments for healthcare services and supplies are frequently based on projections of future costs, often measured against a baseline calculated on past costs. However, COVID-19 and its attendant changes to the...more

King & Spalding

Contracting Checklist for the End of Year

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As we approach the end of the year, many providers are in the process of negotiating renewals of their network contracts with health plans. Below are a few “best practices” ideas for providers to consider as they approach...more

Manatt, Phelps & Phillips, LLP

NYC PHIP Small Practice Project, Final Report

Primary care practices in New York face pressure from payers and regulators to transition to a medical home model and to participate in value-based payment (VBP) contracts. The changes require increased operating costs in a...more

King & Spalding

CMS and OIG Issue Notice of Amended Waivers for Next Generation ACO Model

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On December 29, 2016, CMS and OIG issued a Notice of Amended Waivers of Certain Fraud and Abuse Laws in Connection with the Next Generation ACO Model (the 2016 Notice). The 2016 Notice does not change or limit arrangements...more

McDermott Will & Emery

Managing the Transition to Transformation: Old Dog, New Tricks: Fraud and Abuse in the Age of Payment Reform

McDermott Will & Emery on

McDermott’s Managing the Transition to Transformation series is designed to help health systems and other health care industry leaders address the many challenges presented by the transformation in payment and care delivery...more

Mintz - Health Care Viewpoints

The Managed Care Industry – 2015 Year in Review

As we start a new year, let’s take a look back at a few hot topics that emerged in the managed care industry in 2015 and will likely be drivers of developments in 2016. Industry Consolidation – The Changing Landscape - ...more

King & Spalding

CMS Issues Final Rule for Waivers in Connection With the Shared Savings Program

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On October 29, 2015, CMS issued its Final Rule setting forth waivers of the application of the physician self-referral law (the Stark law), the Federal anti-kickback statute (AKS), and the civil monetary penalties (CMP) law...more

Baker Donelson

Limited Modifications in Final ACO Fraud and Abuse Waivers Most Notably Include Cut of Gainsharing CMP Waiver

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Nearly four years after publishing their joint interim final rule with comment period, effective November 2, 2011 (IFC), the OIG and CMS (Agencies) have finalized the waivers of various fraud and abuse laws in the context of...more

Saul Ewing Arnstein & Lehr LLP

CMS and OIG Issue Final ACO Waivers

On Thursday, October 29, 2015, the Centers for Medicare & Medicaid Services (“CMS”) and the Office of Inspector General (“OIG”) jointly issued a rule (the “Final Rule”) to finalize five (5) waivers of certain fraud and abuse...more

Arnall Golden Gregory LLP

New ACO Data Show Improved Care, Increased Savings in 2014

Medicare Accountable Care Organizations ("ACOs") improved the quality of care they provided and generated financial savings in 2014, according to data recently released by the Centers for Medicare & Medicaid Services ("CMS")....more

Franczek P.C.

DOL Files Complaint Against Plan Fiduciaries for Using 401(k) Contributions and Loan Repayments to Fund Plan Sponsor’s General...

Franczek P.C. on

On April 10, 2015, the DOL filed a complaint against Enterworks, Inc., the Enterworks, Incorporated Shared Savings Plan, and two individual fiduciaries of the Savings Plan (the Defendants). In the complaint, the DOL alleges...more

Saul Ewing Arnstein & Lehr LLP

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

Baker Donelson

ACO Fraud and Abuse Waivers Extended Through November 2, 2015

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On October 17, 2014 the Centers for Medicare and Medicaid (CMS) and Office of Inspector General (OIG) within the Department of Health and Human Services published a continuation notice in the Federal Register extending the...more

King & Spalding

CMS and OIG Extend Interim Final Rule Regarding Waivers of Fraud and Abuse Laws For ACOs

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On October 17, 2014, CMS and OIG jointly published a notice extending the effectiveness of a November 2011 interim final rule establishing waivers that protect qualifying accountable care organizations (ACOs) from liability...more

Manatt, Phelps & Phillips, LLP

Health Update

Assessing the Medicare Shared Savings Program: Diverse Participants, Diverse Results - Rising healthcare costs and declining reimbursements have placed immense pressure on providers and health systems to manage the...more

Dechert LLP

PEA PME-ETI: An Enhanced Version of the French PEA of Interest for EU Asset Managers

Dechert LLP on

A new French tax law, effective since the beginning of this year, has generated much excitement by creating an enhanced favorable tax regime – the PEA PME-ETI – for individual investors. The new regime is similar to the Plan...more

King & Spalding

MyRA: What Employers Need to Know about New Savings Option

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In his State of the Union address on January 28, 2014, President Obama announced the creation of a new retirement savings option. The "my Retirement Account" or "myRA," which will be developed by the U.S. Department of...more

Smith Anderson

A Checklist for Entering Shared Savings Contracts: Practical Considerations

Smith Anderson on

It’s no secret that payment for health care services is moving away from a fee-for-service world that rewards volume towards new value-based models that encourage higher quality and more efficient care. Perhaps no value-based...more

Foley & Lardner LLP

Win, Lose, and Push: CMS Announces First Year Results on the Pioneer ACO Program

Foley & Lardner LLP on

On July 16, 2013, CMS announced results from the first performance year of the Pioneer Accountable Care Organization (ACO) Model. In the release, CMS reported that the Pioneer ACO participants held Medicare cost increases...more

King & Spalding

More Providers Form Accountable Care Organizations; Growth in Medicare Spending Continues to Decrease

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On January 10, 2013, HHS Secretary Kathleen Sebelius announced that 106 new Accountable Care Organizations (ACOs) have formed and begun participating in the Shared Savings Program as of January 1, 2013....more

King & Spalding

Statistical Uncertainty in the Medicare Shared Savings Program

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CMS has released the results of a recent analysis, published in Vol. 2, No. 4 of the Medicare & Medicaid Research Review, entitled Statistical Uncertainty in the Medicare Shared Savings Program....more

Mintz - Health Care Viewpoints

Medicare Shared Savings Program Grows by 106 ACOs in 2013

Yesterday the Centers for Medicare & Medicaid Services formally announced the 106 new Accountable Care Organizations (ACOs) participating in the 2013 Medicare Shared Savings Program (MSSP) cycle. CMS also announced that 15...more

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