Shared Savings Program

News & Analysis as of

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

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

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

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

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

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

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

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

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

ACO Fraud and Abuse Waivers Extended Through November 2, 2015

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

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

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

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

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

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

MyRA: What Employers Need to Know about New Savings Option

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

A Checklist for Entering Shared Savings Contracts: Practical Considerations

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

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

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

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

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

Statistical Uncertainty in the Medicare Shared Savings Program

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

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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