The Centers for Medicare & Medicaid Services’ (“CMS”) Medicare Shared Savings Program final rule offers potential opportunities as well as risks to health care providers and suppliers interested in forming accountable care organizations (“ACOs”). While the core principle of the Medicare Shared Savings Program is simple—reward improvements in quality and cost containment through a share of the resulting savings—the regulatory and operational requirements associated with the program are much more complex.
Reed Smith attorneys have prepared a comprehensive Client Alert summarizing and analyzing the final rule, focusing on provisions we believe are of greatest interest to health care providers and medical device and pharmaceutical manufacturers. We also summarize companion guidance documents published by various federal agencies, including the Office of Inspector General, the Department of Justice, the Federal Trade Commission, and the Internal Revenue Service. Our Alert details changes from the proposed rule, discusses CMS’s response to public comments, identifies the practical impact of the final rule, and flags questions and concerns associated with the program.
In addition, Reed Smith will be hosting a teleseminar on this topic Wednesday, December 7, 2011.
Click here to read the full Alert (PDF).