Strategy and Options for Alignment and Steps to Create an ACO

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Strategy and Options for Alignment and Steps to Create an ACO"

Transcription

1 White Paper Strategy and Options for Alignment and Steps to Create an ACO A Suggested Strategy James M. Daniel, Jr., JD, MBA Hancock, Daniel, Johnson & Nagle, P.C. (866) P.O. Box Richmond, Virginia Phone (804) Fax (804)

2 Table of Contents Executive Summary... 1 I. ACO Background... 2 II. Our Approach... 3 A. Develop Leadership and Vision... 3 B. Develop an Engaged Provider Network... 3 C. Establish a PHO or Proprietary Network... 3 D. Electronic Health Record System and Information Sharing... 5 E. Enrollment... 6 F. Peer Review Body... 6 G. Patient Safety Organization... 7 H. Pay-For-Performance and Gainsharing... 7 I. Additional Features Management Services Organization Joint Purchasing Arrangements Risk Purchasing Group Physician Hospital Organization Tag-Along PHO MEWA Clinical Co-Management Professional Employee Organization Credentialing Verification Organization Recruitment Assistance Physician Leadership Standard of Care Teams Continuing Medical Education Other Services III. Conclusion... 11

3 Executive Summary The text that follows outlines a strategy for creating an interim step to a fully implemented ACO. The critical element to creating an ACO is in establishing a contracting vehicle, either as a proprietary network or as a PHO model. The network needs to be established to engage a group of physicians who are clinically integrated, who share an electronic health record system and who agree to actively share and process information to develop evidence based order sets. Participation in the network, either in total or on a contract-by-contract basis, needs to be linked to the willingness on the part of physicians to adhere to these guidelines. Given the large degree of information that will be shared and the work product that will be generated, the ACO s operations should be conducted in a peer review protected environment. As one option, the network would be only partially integrated in that the health system might own/employ a number of the elements of the provider chain, but would invite and include non-employed (unaffiliated) physicians and potentially other providers, such as post acute providers, as participants in the network. Under a parallel track, payment mechanisms should be developed either internally (i.e. a network of provider employees) or with employer or employer groups out of managed care plans. Insurance companies have communicated a desire to develop pilot programs for payment mechanisms to operate as an alternative fee for service. The proprietary network or PHO should operate in the interim as a typical managed care contract and should offer a number of benefits to affiliated physicians in order to provide the benefits of alignment/affiliation while the markets for ACOs mature. Page 1

4 I. ACO Background. To begin, in its most general sense, an ACO is an organization of providers that takes collective responsibility for improving patient care. The focus of this memorandum is on the Medicare ACO opportunity and ACO-look-alike options available with private health insurance plans. The ACO concept has existed for some time with innovative programs such as the Brookings-Dartmouth Pilot Project designed to incent efficient healthcare and quality outcomes through arrangements with private insurance companies. The Patient Protection and Affordable Care Act of 2010 ( PPACA ) accelerated the push towards accountable delivery models, with federal money becoming available as soon as January 1, 2012 under the Medicare Shared Savings Program. To participate in the Medicare program, the ACO must: Have a formal legal structure to receive and distribute shared savings; Include sufficient number of primary care professionals for the assigned beneficiaries; Have a minimum of 5,000 assigned beneficiaries ; Agree to participate for no less than three years; Document information regarding participating health professionals to support beneficiary assignment; Implement a leadership and management structure that includes clinical and administrative systems; Define processes that promote evidence-based medicine; report data for quality and cost measures; and coordinate care; Demonstrate a model of patient-centeredness. Page 2

5 While interest in the Medicare ACO program is high, many providers are electing to take a wait-and-see approach as best practices emerge. In reality, until CMS revises the Stark rules on physician-self referral, the government s vision for accountable care, in many instances, cannot be achieved without incurring regulatory risk. Others are opting to participate in private pilot programs in order to experiment with the wide range of variables to best develop their ACO infrastructure. Regardless of approach, the consensus is that clinical integration will be essential. Clinical integrations options include: (i) professionals in a group practices; (ii) networks of individual providers; (iii) hospitals that employ physicians; and (iv) partnerships or joint ventures between hospitals and physicians. II. A Suggested Approach. A. Develop Leadership and Vision. Hospitals should be identifying strategically important, high performing physicians committed to the goals of the organization. Strategically important physicians include those who would expand primary care access, bring needed specialty services to the community, and increase capacity to meet the community demand. These physicians should be open to collaboration and share the organizational vision. Finally, desirable partners would have a demonstrable record of delivering high-quality care and an ability to work within a community of providers to manage chronic disease. B. Develop an Engaged Provider Network. To engage physicians, physician leaders should be empowered with the tools to succeed, which would entail expanding opportunities for physician involvement in the governance and management of the enterprise. The organization would delegate many practice level strategies to physicians. Physicians antagonistic to the enterprise can be engaged through co-management efforts to foster collaboration and mutual accountability. C. Establish a PHO or Proprietary Network. A health system would direct a hybrid model consisting of a jointly owned entity, controlled by the health Page 3

6 system, but with significant physician involvement in governance and management, that contracts with its participants for the care of defined patient populations and that distributes a revenue pool in a way that rewards high performance on a basis that is not fee-for-service dominated. The model would possess the following attributes: Clinical integration; Joint contracting for services; Pay-for-Performance platform; Penalties for variance on select measures; Information technology infrastructure for data sharing and benchmarking; and A confidential platform for the development of best practices and evidence based standards. Successful networks should start small and layer additional features once the organization has chosen strong partners whose contributions will advance the organization s goals of efficiency and improved quality. Using the lessons of the PHO model, the ability share information, coordinate care, track results, develop clinical protocols, and enforce standards is essential to clinical integration. To promote participation in this network, the organization should adhere to the following strategic imperatives: Secure seed money for investments in transformed delivery structures; Limit risk and disruption through incremental, small pilots; Test innovative accountable care models through controlled models, such as an owned health plan or an insured employee base - many insurance Page 4

7 companies have expressed a willingness to participate in these experimental programs; Leverage clinical competence and demonstrated results to gain payer and physician interest in pilots; Capture first-mover advantage by establishing the rules of the game for the market; Work directly with large employers, or pursue a strategy such as clinical integration if payer negotiations prove difficult; Ensure contract language, risk adjustment, and attribution are well defined yet flexible should implementation hurdles require program changes; Determine readiness for Medicare accountable care models; and Prepare an exit strategy if experiments do not go as planned, such as loss ceilings, upside-only distribution structures, and opt-out clauses. D. Electronic Health Record System and Information Sharing. Using a common EHR to link the participants and sharing information to allow quality benchmarking and improvement would be made conditions of network participation. The common EHR system would be the building block of the affiliation. By conditioning the EHR subsidies on network participation, the health system could impose certain joint activities to further efficiency and quality, and importantly, allow participants to reduce costs. One of the elements would be consent to use their information through a shared profile to improve quality, profile physicians utilization, and establish best practice protocols. Taking advantage of the Stark exception for donation of EHR software, Hospitals can use EHR subsidies to spur physician participation. For example, physicians who agree to become part of the hospital s electronic health record Page 5

8 system and participate in its peer review activities might be eligible for up to 85% of the cost of the EHR software (the maximum subsidy allowed under the Stark exception). E. Enrollment. The ACO would likely need to obtain a separate National Provider Identification Number (NPI) to participate in the Medicare Shared-Savings Program or for contracting directly with other payors. Although regulatory guidance has not yet been provided by CMS, ACOs that participate in the Medicare Shared Savings Program may also need to enroll as providers through the completion of a separate Form 855. F. Peer Review Body. The ability to electronically compile and share information through EHR systems would facilitate the implementation of quality assessment and peer review activities and benchmarking. The health system should review the laws and regulations in its state applicable to peer review to determine how it may be performed outside of the hospital setting. Even in the absence of statutory authority, there are several cases from various jurisdictions that support the ability of peer review organizations to share peer review information with similar organizations without jeopardizing the privileged nature of the information. A note of caution: any organization that engages in office-based peer review and that shares peer review information among network participants should closely adhere to its policies or risk being viewed as having engaged in sham peer review, resulting in the loss of the privilege. The following passage from a 2010 Vermont decision is particularly cautionary of this point: Because the dividing line between peer review and normal business operations can be unclear, courts generally apply the peer review privilege only when the formalities of a peer review process are clearly apparent. For example, conversations between a department chief and nurses will not be protected from discovery if there were no apparent peer review formalities... Formalities such as designated committees and explicitly labeled peer-review reports act as a Page 6

9 signal to medical employees, telling them when their opinions will be protected from discovery. Robinson v. Springfield Hospital, No. 109-CV-75, slip op. at 2 (D. Vt. Feb. 5, 2010) (emphasis added). In other words, stamping documents "Confidential - Peer Review," controlling the distribution of peer review documents, and taking other practical steps to maintain confidentiality are important to protecting peer review information. G. Patient Safety Organization. Going further, the ACO could interface with a patient safety organization ( PSO ), which would operate in conjunction with the peer review body. PSOs can be key tools in aggregating and analyzing data, establishing benchmarks, and conducting educational activities and corrective action plans. With a PSO, the aligned organization would have the ability to enforce network-wide protocols and quality of care standards. With a shared EHR system, an active peer review body and a PSO in place, the organization could efficiently exchange information regarding patients and practice experience, collect and analyze such information to improve treatment quality, rates of utilization and cost containment, monitor physician compliance and performance with physician-authored benchmarks, protocols and standards, and enforce consequences for non-compliance. H. Pay-For-Performance and Gainsharing. As healthcare moves away from the fee-for-service payment structure, the government is acknowledging that compensation structures that reward quality and efficiency can be valuable tools in reigning in the costs of healthcare. For example, in 2008, the OIG was asked to evaluate a pay-for-performance arrangement under which the hospital, which was rewarded by private insurers for improving efficiency and improving quality, would pay a physician-entity up to 50% of the bonus compensation received by the hospital Page 7

10 for meeting quality targets. In turn, the physician entity would distribute revenues on a per capita basis to its physicians. The program also included a cap on payments to the physician entity, which was tied to the base compensation paid by the commercial insurer to the hospital. Thus, any increase in patient referrals to the hospital would not increase the annual payment to the physicians. The hospital was also responsible for monitoring any inappropriate reductions or limitations on patient care. The OIG declined to impose penalties under the anti-kickback statute because the program had sufficient safeguards to reduce the risk of fraud and abuse. Advisory Opinion stands as a significant decision because is shows the OIG s willingness to allow new gainsharing arrangements, such as programs involving thirdparty commercial insurers using quality standards that are based on credible medical standards and contain appropriate safeguards against fraud and abuse. I. Additional Features. The affiliation between the health system and physicians might also include other add-ons, such as the options outlined below, which could be incorporated into the primary affiliation agreement through individual addenda. 1. Management Services Organization. It typically provides administrative services, non-physician personnel, and decision-making support in exchange for a flat fee or percentage of revenues. These organizations provide reasonably priced help with some of the more onerous administrative aspects of their practices. 2. Joint Purchasing Arrangements. Capitalizing on economies of scale, a joint purchasing arrangement would allow products or services to be purchased and negotiated by a single (independent) purchaser for the hospital and the ACO participants. Page 8

11 3. Risk Purchasing Group. A Risk Purchasing Group is an organization which purchases liability insurance on a group basis from an insurance company or a risk retention group for its members. This would provide the option of physicians to purchase malpractice insurance on a group basis (hopefully at a discount), to what is otherwise available in the market. Additionally if the hospital were to sponsor this type of vehicle, there are other options that could be considered such as vicarious liability for the hospital and joint defense arrangements. 4. Physician Hospital Organization. A PHO acts as a clearinghouse for managed care contracting and, in some cases, other administrative functions. This model allows both the hospital and the physicians to maintain autonomy over their respective operations, but helps consolidate and reduce administrative costs. Because of antitrust/price-fixing concerns associated with competing physician groups sharing payor reimbursement information, some hospitals have created variations on the traditional PHO, such as a PHO that only admits one group of each specialty. PHO participation for hospital physicians can be mandatory or voluntary. Any PHO must be carefully planned such that any collective negotiations do not violate anti-trust laws. Section 1 of the Sherman Act prohibits any contract, combination, or conspiracy that unreasonably restrains competition. Agreements between competing physicians, or other health care providers, on the prices to be charged for their individual services are agreements in restraint of competition and are generally illegal, absent a showing of substantial financial or clinical integration. 5. Tag-Along PHO. The FTC has not challenged an employer s ability to negotiate on behalf of its employed physicians because they are a single economic unit. Some hospitals and PHOs have adopted a system where they take the prices they have negotiated for their employed physician and then ask the payor if they can offer the same price to other providers (i.e., they are just acting as a messenger). This arrangement is generally acceptable, so long as the hospital does Page 9

12 not imply that the payors have to take on all the PHO providers or they won t sign the employed physicians. 6. MEWA. MEWA is an acronym for Multiple Employer Welfare Arrangement and is any plan or arrangement established to offer or provide coverage for health care services to employees of two or more employers. MEWAs are often used as another vehicle to enhance negotiating power through increased pool size. 7. Clinical Co-Management. Physicians and hospitals create a limited liability company or other entity to provide management services for a specific clinical department. By making management concessions, a hospital will engender greater cooperation and trust with its physician partners. The management company is paid a fair market value fee for its services, which is divided among the hospital and the physicians in accordance with their ownership interests. 8. Credentialing Verification Organization. As many providers or small plans can not perform credentialing in a cost-effective manner, they may outsource this function to credentialing verification organizations (CVOs). CVOs should be certified by the National Committee on Quality Assurance (NCQA) to ensure that their services meet those standards. 9. Recruitment Assistance. For those practices that do not wish to be fully integrated, hospitals may offer recruitment assistance packages to encourage the group to hire new talent (who will hopefully also refer to the hospital). These programs typically include income guarantees, student loan forgiveness, and relocation packages. Page 10

13 10. Physician Leadership. The hospital includes physician-leaders on its board and/or major committees and as officers. If physicians feel that their interests are more adequately represented in the decision-making process and understand the financial factors involved, they are more likely to comply with hospital policies, to support cost-saving methods and to refer to the hospital. They will also have fiduciary responsibilities to the hospital. 11. Standard of Care ( SOC ) Teams. SOC teams and physician advisory boards are often created through these types of mechanisms. In some instances, they may be allowed to be in compensated positions, to provide leadership and development of clinical evidence based sets and assist in clinical redesign that will allow the providers to operate better in the health reform environment. 12. Continuing Medical Education. The affiliated entity could sponsor continuing medical education programs for its participating physicians. 13. Other Services. The ACO might also offer the following services to its participants: fee comparison; CPT code analysis; payer mix analysis; and handling of Medicare, Medicaid and NPI applications. III. Conclusion The urgency of reducing healthcare costs while increasing quality is resulting in rapid and fundamental changes in the delivery of and reimbursement for healthcare in the United States. Collective responsibility among groups of providers to achieve quality outcomes is viewed as a viable alternative to fee-forservice reimbursement. The prevalence of these delivery structures is likely to grow. Organizations that respond to these emerging changes will benefit from the steps they take now to develop the affiliations and infrastructure needed to succeed in an outcome-driven environment. Page 11

INTEGRATION STRATEGIES FOR A NEW HEALTH CARE ECONOMY

INTEGRATION STRATEGIES FOR A NEW HEALTH CARE ECONOMY INTEGRATION STRATEGIES FOR A NEW HEALTH CARE ECONOMY Thomas William Baker Baker Donelson Bearman Caldwell & Berkowitz, P.C. Atlanta, Georgia (404) 221-6510 tbaker@bakerdonelson.com Prepared for East Georgia

More information

Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare

Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare December 2010 Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare CONTENTS Background... 2 Problems with the Shared Savings Model... 2 How

More information

Hospital and Independent Physician Alignment: Structural Options, Business and Compliance Considerations

Hospital and Independent Physician Alignment: Structural Options, Business and Compliance Considerations Hospital and Independent Physician Alignment: Structural Options, Business and Compliance Considerations By Bruce A. Johnson and Janice Anderson I. Introduction Numerous policy initiatives are now being

More information

BAKER DONELSON BAKER S DOZEN

BAKER DONELSON BAKER S DOZEN Thirteen Things Health Care Providers Should Know About Accountable Care Organizations and Health Reform Thomas E. Bartrum, 615.726.5641, tbartrum@bakerdonelson.com With passage of the Patient Protection

More information

2010 MHA Governance Leadership Forum: Accountable Care Organizations. Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan

2010 MHA Governance Leadership Forum: Accountable Care Organizations. Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan 2010 MHA Governance Leadership Forum: Accountable Care Organizations Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan Overview Major health care payment reform under the Affordable Care Act (

More information

DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM

DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM 1 DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM Definition of ACO General Concept An ACO refers to a group of physician and other healthcare providers and suppliers

More information

Accountable Care Organizations and Provider Integration Under Health Care Reform. Sarah Swank 202.326.5003 seswank@ober.com

Accountable Care Organizations and Provider Integration Under Health Care Reform. Sarah Swank 202.326.5003 seswank@ober.com Accountable Care Organizations and Provider Integration Under Health Care Reform Sarah Swank 202.326.5003 seswank@ober.com February 26, 2014 Overview Affordable Care Act and ACOs Trends in Integration

More information

Accountable Care Organizations. Rick Shinto, MD Aveta Health Inc. July 20, 2010

Accountable Care Organizations. Rick Shinto, MD Aveta Health Inc. July 20, 2010 Accountable Care Organizations Rick Shinto, MD Aveta Health Inc. July 20, 2010 1 Health Care Reform- New Models of Care Patient Protection and Affordable care Act (PPACA 2010) controlling costs and improving

More information

Provider Participation in ACOs May Hinge on HHS Regulations

Provider Participation in ACOs May Hinge on HHS Regulations Source: Health Law Reporter: News Archive > 2010 > 04/15/2010 > BNA Insights > Provider Participation in ACOs May Hinge on HHS Regulations Provider Participation in ACOs May Hinge on HHS Regulations 19

More information

The Cornerstones of Accountable Care ACO

The Cornerstones of Accountable Care ACO The Cornerstones of Accountable Care Clinical Integration Care Coordination ACO Information Technology Financial Management The Accountable Care Organization is emerging as an important care delivery and

More information

Accountable Care Organizations: What Providers Need to Know

Accountable Care Organizations: What Providers Need to Know DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Accountable Care Organizations: FACT SHEET Overview http://www.cms.gov/sharedsavingsprogram On October 20, 2011, the Centers

More information

Accountable Care Organizations

Accountable Care Organizations Building a Healthy ACO Compliance Program HCCA 2014 Compliance Institute Mary C. Malone, Esq. Hancock, Daniel, Johnson & Nagle, P.C. Disclaimer: The content of this presentation does not constitute legal

More information

Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones

Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones Public Workshop hosted by the FTC, CMS, HHS OIG October

More information

To Be or Not To Be Independent, That Is The Question. Lisa Chase Law Offices of Lisa Chase, P.C. chase@lchaselaw.

To Be or Not To Be Independent, That Is The Question. Lisa Chase Law Offices of Lisa Chase, P.C. chase@lchaselaw. To Be or Not To Be Independent, That Is The Question Lisa Chase Law Offices of Lisa Chase, P.C. chase@lchaselaw.com (520) 623-6262 Overview Private Practice Trends Benefits of Independence Threats and

More information

KATHLEEN L. DEBRUHL & ASSOCIATES, L.L.C. 614 TCHOUPITOULAS STREET NEW ORLEANS, LOUISIANA 70130 504.522.4054 (OFFICE) 504.522.9049 (FAX) WWW.MD-LAW.

KATHLEEN L. DEBRUHL & ASSOCIATES, L.L.C. 614 TCHOUPITOULAS STREET NEW ORLEANS, LOUISIANA 70130 504.522.4054 (OFFICE) 504.522.9049 (FAX) WWW.MD-LAW. CMS RELEASES PROPOSED ACCOUNTABLE CARE ORGANIZATION REGULATIONS By: Kathleen L. DeBruhl, Esq. and Lindsey E. Surratt, Esq. On March 31, 2011, the Centers for Medicare and Medicaid Services ( CMS ) issued

More information

Legal Challenges and Concerns with Clinical Integration

Legal Challenges and Concerns with Clinical Integration Legal Challenges and Concerns with Clinical Integration By Edward Matto and Claire Turcotte, Bricker & Eckler LLP A clear goal of health reform is to foster greater integration and collaboration among

More information

Accountable Care Organizations The Future Integrated Health Care Delivery Model?

Accountable Care Organizations The Future Integrated Health Care Delivery Model? Accountable Care Organizations The Future Integrated Health Care Delivery Model? Maria T. Currier Randy Fenninger Holland & Knight LLP Adventist Health System Annual Legal Retreat October 25, 2010 Orlando,

More information

Medicare ACO Road Map

Medicare ACO Road Map PYALeadership Briefing Medicare ACO Road Map January, 2013 Medicare ACO Road Map The Centers for Medicare & Medicaid Services ( CMS ) has announced 106 new accountable care organizations ( ACOs ) have

More information

How Health Reform Will Affect Health Care Quality and the Delivery of Services

How Health Reform Will Affect Health Care Quality and the Delivery of Services Fact Sheet AARP Public Policy Institute How Health Reform Will Affect Health Care Quality and the Delivery of Services The recently enacted Affordable Care Act contains provisions to improve health care

More information

Accountable Care Organizations: An old idea with new potential. Stephen E. Whitney, MD, MBA Testimony to Senate State Affairs September 22, 2010

Accountable Care Organizations: An old idea with new potential. Stephen E. Whitney, MD, MBA Testimony to Senate State Affairs September 22, 2010 Accountable Care Organizations: An old idea with new potential Stephen E. Whitney, MD, MBA Testimony to Senate State Affairs September 22, 2010 Impetus for ACO Formation Increased health care cost From

More information

PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES

PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES The Centers for Medicare and Medicaid Services (CMS) and other affected agencies released their notice of proposed rulemaking/request for comment for

More information

Who, What, When and How of ACOs. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Who, What, When and How of ACOs. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program Who, What, When and How of ACOs Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program April 5, 2011 On March 31, 2011, the Centers for Medicare

More information

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs)

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) By: Chris Rossman, Foley & Lardner LLP, Detroit, Michigan 1. The Centers for Medicare and Medicaid Services ( CMS ) and the Office

More information

Additional Information About Accountable Care Organizations

Additional Information About Accountable Care Organizations Additional Information About Accountable Care Organizations For more information, please contact: April 2011 On March 31st, the federal government outlined proposed actions relating to Accountable Care

More information

CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS

CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS Claire Turcotte, Esquire, Bricker & Eckler LLP Jim Yanci, MS MT (ASCP), Dixon Hughes Goodman Agenda BUSINESS CONSIDERATIONS How Fast are

More information

Healthcare Reform Update Conference Call VI

Healthcare Reform Update Conference Call VI Healthcare Reform Update Conference Call VI Sponsored by the Healthcare Reform Educational Task Force October 9, 2009 2:00-2:45 2:45 pm Eastern Healthcare Delivery System Reform Provisions in America s

More information

August 12, 2010. Dear Dr. Berwick:

August 12, 2010. Dear Dr. Berwick: Donald M. Berwick, MD Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Room 314G Washington, DC 20201 Dear Dr. Berwick: I am

More information

The Accountable Care Organization

The Accountable Care Organization The Accountable Care Organization Kim Harvey Looney kim.looney@ 615-850-8722 3968555 1 ACOs: Will I Know One When I See One? Relatively New Concept Derived from Various Demonstration Programs No Set Structure

More information

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS Briefing Paper on the Proposed Medicare Shared Savings Program The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to implement

More information

CMS Releases Proposed Rule Governing Accountable Care Organizations

CMS Releases Proposed Rule Governing Accountable Care Organizations CMS Releases Proposed Rule Governing Accountable Care Organizations Health Care Organizations Face Complex Strategic Decisions Authors: Robert D. Belfort Paul M. Campbell Susan R. Ingargiola Stephanie

More information

Large Urology Group Practice Association. Accountable Care Organizations

Large Urology Group Practice Association. Accountable Care Organizations Large Urology Group Practice Association Accountable Care Organizations November 6, 2010 J. Phillip O Brien 312.902.5630 phillip.obrien@kattenlaw.com Basic Premise for ACOs Facilitate medical care coordination

More information

The Stark Law Opportunities to Address Barriers to Clinical Integration January 29, 2016

The Stark Law Opportunities to Address Barriers to Clinical Integration January 29, 2016 The Stark Law Opportunities to Address Barriers to Clinical Integration There are several rules governing compensation relationships between hospitals, physicians and other caregivers, including the Anti-kickback

More information

Master of Health Administration

Master of Health Administration Master of Health Administration THE IMPACT OF CLINICAL INTEGRATION ON JOINT MANAGED CARE CONTRACTING AMONG INDEPENDENT PHYSICIANS MARC MERTZ Executive Master of Health Administration Candidate, 2011 University

More information

OHIO HOSPITAL ASSOCIATION 2015 Annual Meeting. Accountable Care Organizations Comprehensive Integration Strategy

OHIO HOSPITAL ASSOCIATION 2015 Annual Meeting. Accountable Care Organizations Comprehensive Integration Strategy OHIO HOSPITAL ASSOCIATION 2015 Annual Meeting Accountable Care Organizations Comprehensive Integration Strategy ACO Development Market Conditions Increasing Economic pressures Consumerism Regulatory scrutiny

More information

CMS proposed rule on ACOs: http://www.gpo.gov/fdsys/pkg/fr-2011-04-07/pdf/2011-7880.pdf

CMS proposed rule on ACOs: http://www.gpo.gov/fdsys/pkg/fr-2011-04-07/pdf/2011-7880.pdf April 7, 2011 Dear Physician Colleague: On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) issued its long awaited proposed regulations on the Medicare Shared Savings/Accountable Care

More information

G-2. Report. Compliance. An ambitious health reform subtitle, Transforming the Health

G-2. Report. Compliance. An ambitious health reform subtitle, Transforming the Health G-2 Kimberly Scott, Managing Editor, kscott@ioma.com Carrie Valiant is a senior member of the health care and life sciences practice of the national law firm, EpsteinBeckerGreen, practicing in its Washington,

More information

Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011

Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011 Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011 On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) released the longawaited proposed rule on Accountable Care

More information

Accountable Care: Clinical Integration is the Foundation

Accountable Care: Clinical Integration is the Foundation Solutions for Value-Based Care Accountable Care: Clinical Integration is the Foundation Clinical Integration Care CoordinatioN ACO Information Technology Financial Management The Accountable Care Organization

More information

Legal Issues for Accountable Care Organizations

Legal Issues for Accountable Care Organizations Legal Issues for Accountable Care Organizations Health Care Reform Strategies Bruce Merlin Fried, Esq. ACO Summit June 7, 2010 ACOs in PPACA The Basics Section 3022 of the Protection and Affordable Care

More information

Accountable Care Organizations: Experiences, Examples and Lessons Learned

Accountable Care Organizations: Experiences, Examples and Lessons Learned Accountable Care Organizations: Experiences, Examples and Lessons Learned New York State Academy of Family Physicians Downstate Regional Family Medicine Conference Jeffrey R. Ruggiero Arnold & Porter LLP

More information

Accountable Care Organizations: Reality or Myth?

Accountable Care Organizations: Reality or Myth? Written by: Ty Meyer Accountable Care Organizations: Reality or Myth? Introduction According to Steven Gerst, VP of Medical Affairs at MedCurrent Corporation, The Patient Protection and Affordable Care

More information

Mar. 31, 2011 (202) 690-6145. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Mar. 31, 2011 (202) 690-6145. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Room 352-G 200 Independence Avenue, SW Washington, DC 20201 Office of Media Affairs MEDICARE FACT SHEET FOR IMMEDIATE RELEASE

More information

Study Guide: Quality Management

Study Guide: Quality Management Study Guide: Quality Management Outline: Below is a brief outline of the course. Introduction The goal is to reduce the outcome variability of key processes, thus reducing waste, increasing efficiency

More information

Entities eligible for ACO participation

Entities eligible for ACO participation On Oct. 20, 2011, the Centers for Medicare & Medicaid Services (CMS) finalized new rules under the Medicare Shared Savings Program (MSSP) to help doctors, hospitals, and other health care providers better

More information

ACO Type Initiatives

ACO Type Initiatives If you proposed an ACO initiative, please fill our this Comparison of Elements for Participation in Medicare Shared Savings Program (MSSP) to State SIM ACO Test Proposal From Funding Opportunity Announcement:

More information

Accelerating Clinical Integration

Accelerating Clinical Integration Accelerating Clinical Integration A collaborative white paper written by: Kenneth H. Cohn, MD, MBA, FACS, CEO of Healthcare Collaboration Peter A. Pavarini, J.D., partner at Squire Sanders (US) LLP, Executive

More information

Federal Health Care Reform: Implications for Hospital and Physician partnerships. Walter Kopp Medical Management Services

Federal Health Care Reform: Implications for Hospital and Physician partnerships. Walter Kopp Medical Management Services Federal Health Care Reform: Implications for Hospital and Physician partnerships Walter Kopp Medical Management Services Outline Overview of federal health reform legislation Implications for Care delivery

More information

Accountable Care Organization Refinement Brief

Accountable Care Organization Refinement Brief Accountable Care Organization Refinement Brief The participants in the Medicare Shared Savings Program (MSSP), the Physician Group Practice Transition Demonstration (PGP-TD), and the Pioneer Accountable

More information

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS Briefing Paper on the Proposed Medicare Shared Savings Program The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to implement

More information

Fraud & Abuse Waivers Under the Medicare Shared Savings Program

Fraud & Abuse Waivers Under the Medicare Shared Savings Program Fraud & Abuse Waivers Under the Medicare Shared Savings Program Robert G. Homchick Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

II. SHARED SAVINGS PROGRAM AND COST-REDUCTION INCENTIVES

II. SHARED SAVINGS PROGRAM AND COST-REDUCTION INCENTIVES E-ALERT Health Care April 15, 2011 ACCOUNTABLE CARE ORGANIZATION BASICS The Affordable Care Act establishes the Medicare Shared Savings Program ( Program ), which provides for the development of accountable

More information

AHLA. BB. Accountable Care Organizations and the Medicare Shared Savings Program. Troy Barsky Crowell & Moring LLP Washington, DC

AHLA. BB. Accountable Care Organizations and the Medicare Shared Savings Program. Troy Barsky Crowell & Moring LLP Washington, DC AHLA BB. Accountable Care Organizations and the Medicare Shared Savings Program Troy Barsky Crowell & Moring LLP Washington, DC Daniel F. Murphy Bradley Arant Boult Cummings LLP Birmingham, AL Terri L.

More information

group practice journal

group practice journal group practice journal P U B L I C A T I O N O F T H E A M E R I C A N M E D I C A L G R O U P A S S O C I A T I O N Reprinted from Electronic Health Record Offers: What s a Doctor to Do? BY ELLEN F. KESSLER,

More information

Cornerstone Health Care, P.A.

Cornerstone Health Care, P.A. Cornerstone Health Care, P.A. Medicare Shared Savings Program ACO Compliance NAACOS July 2013 Agenda 1. Background 2. Compliance Requirements & Purpose 3. Cornerstone s experience 4. Q&A 2 Cornerstone

More information

Accountable Care Organizations Understanding What They Are and How to Structure Them

Accountable Care Organizations Understanding What They Are and How to Structure Them Accountable Care Organizations Understanding What They Are and How to Structure Them Maria T. Currier HOLLAND & KNIGHT LLP Miami Chamber of Commerce Healthcare Subcommittee December 7, 2010 Copyright 2010

More information

PHI IN THE ACO. Risk Management, Mitigation and Data Collection Issues. Online Tech Webinar May 20, 2014. Tatiana Melnik, Attorney Melnik Legal PLLC

PHI IN THE ACO. Risk Management, Mitigation and Data Collection Issues. Online Tech Webinar May 20, 2014. Tatiana Melnik, Attorney Melnik Legal PLLC PHI IN THE ACO Risk Management, Mitigation and Data Collection Issues Online Tech Webinar May 20, 2014 Tatiana Melnik, Attorney Melnik Legal PLLC Carrie Nixon, Attorney, CEO Nixon Law Group Healthcare

More information

Accountable Care Organizations (ACOs) Work Group. March 6, 2014

Accountable Care Organizations (ACOs) Work Group. March 6, 2014 Accountable Care Organizations (ACOs) Work Group March 6, 2014 Agenda Welcome Introductions Agency Presentation Statutory Authorization for ACOs Work Group Charge Insurance Law Background Overview of Draft

More information

ACOs: Six Things Specialty Practices Should Know

ACOs: Six Things Specialty Practices Should Know ACOs: Six Things Specialty Practices Should Know =TOS Newsletter, July/August 2014= Authors: John P. Schmitt, Ph.D. and J. Garrett Schmitt, MBA, PCMH CCE INTRODUCTION Do you remember the analogy of four

More information

HEALTH CARE LAW. Accountable Care Organizations

HEALTH CARE LAW. Accountable Care Organizations HEALTH CARE LAW September 10, 2010 Presented by University of Mississippi Center for Continuing Legal Education Topic: Accountable Care Organizations By Jonell Beeler Baker, Donelson, Bearman, Caldwell

More information

PPACA: IMPACT ON MEDICAL PRACTICES AND CARE DELIVERY ROSA FINI, M.D. APRIL 2013

PPACA: IMPACT ON MEDICAL PRACTICES AND CARE DELIVERY ROSA FINI, M.D. APRIL 2013 PPACA: IMPACT ON MEDICAL PRACTICES AND CARE DELIVERY ROSA FINI, M.D. APRIL 2013 1 A SYSTEMS ORGANIZATION CHANGE COMPREHENSIVE SYSTEM REFORM IMPACTS: REIMBURSEMENT MECHANISMS MEDICAL CARE DELIVERY MODEL

More information

HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS

HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS PRESENTED AT THE NASABA 2011 CONVENTION BY: PURVI B. MANIAR Context and Background Patient Protection and Affordable Care Act of 2010 ( PPACA ) (Section

More information

ACOs ECONOMIC CREDENTIALING BUNDLING OF PAYMENTS

ACOs ECONOMIC CREDENTIALING BUNDLING OF PAYMENTS ACOs ECONOMIC CREDENTIALING BUNDLING OF PAYMENTS There are a number of medical economic issues Headache Medicine Physicians should be familiar with as we enter a new era of healthcare reform. Although

More information

Payor Perspectives on Provider Realignment and ACOs

Payor Perspectives on Provider Realignment and ACOs Payor Perspectives on Provider Realignment and ACOs Joel L. Michaels March 15, 2011 Overview Issues to be addressed Medicare Shared Savings Program overview ACO organization options Health care reform

More information

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program IMPLEMENTING COMPLIANCE PROGRAMS FOR ACCOUNTABLE CARE ORGANIZATIONS Amy K. Fehn I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program The Medicare Shared Savings Program

More information

ACA Strategy. Why ACOs? 4/16/2014 ACCOUNTABLE CARE ORGANIZATIONS UNDER THE AFFORDABLE CARE ACT

ACA Strategy. Why ACOs? 4/16/2014 ACCOUNTABLE CARE ORGANIZATIONS UNDER THE AFFORDABLE CARE ACT ACCOUNTABLE CARE ORGANIZATIONS UNDER THE AFFORDABLE CARE ACT Stephen P. Williams, JD 864 350 5276 1984carrera@gmail.com ACA Strategy One of the main ways the Affordable Care Act seeks to reduce health

More information

The Role of Accountable Care Organizations in the New World of Federal and State Health Care Reform

The Role of Accountable Care Organizations in the New World of Federal and State Health Care Reform The Role of Accountable Care Organizations in the New World of Federal and State Health Care Reform May 5, 2010 Daniel T. Roble Ropes & Gray LLP daniel.roble@ropesgray.com 617.951.7476 Michele M. Garvin

More information

Summary of Final Rule Provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Summary of Final Rule Provisions for Accountable Care Organizations under the Medicare Shared Savings Program DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Summary of Final Rule Provisions for Accountable Care Overview The Centers for Medicare & Medicaid Services (CMS), an agency

More information

January 14, 2011. Dear Chairman Issa:

January 14, 2011. Dear Chairman Issa: The Honorable Darrell Issa Chairman Committee on Oversight and Government Reform U.S. House of Representatives 2157 Rayburn House Office Building Washington, D.C. 20515 Dear Chairman Issa: On behalf of

More information

MetroCare/HealthChoice Trilogy Clinically Integrated Network FAQs

MetroCare/HealthChoice Trilogy Clinically Integrated Network FAQs MetroCare/HealthChoice Trilogy Clinically Integrated Network FAQs 1. What is clinical integration? Clinical integration is a new model for healthcare delivery that promotes collaboration among a community

More information

The Regulations Are Out: Is An ACO Right For You? Moderator David Pursell 816.983.8190 david.pursell@huschblackwell.com

The Regulations Are Out: Is An ACO Right For You? Moderator David Pursell 816.983.8190 david.pursell@huschblackwell.com The Regulations Are Out: Is An ACO Right For You? Moderator David Pursell 816.983.8190 david.pursell@huschblackwell.com Today s Discussion Overview of the ACO Regulations Alternatives to a Medicare ACO

More information

Post-Acute/Long- Term Care Planning for Accountable Care Organizations

Post-Acute/Long- Term Care Planning for Accountable Care Organizations White Paper Post-Acute/Long- Term Care Planning for Accountable Care Organizations SCORE A Model for Using Incremental Strategic Positioning as a Planning Tool for Participation in Future Healthcare Integrated

More information

CMS ACO Proposed Regulations

CMS ACO Proposed Regulations CMS ACO Proposed Regulations May 2011 Proposed CMS ACO Regulations Proposed Regulations issued March 31, 2011 Comments due back June 6, 2011 Requires 3 year binding commitment Formal Legal Structure Required

More information

Future of Health Care: How Do You Fit In? Physician Leadership Institute February 28, 2015 Brian M. McCook, CPA

Future of Health Care: How Do You Fit In? Physician Leadership Institute February 28, 2015 Brian M. McCook, CPA Future of Health Care: How Do You Fit In? Physician Leadership Institute February 28, 2015 Brian M. McCook, CPA Learning Objectives Industry Transitions Challenges and Changes ACO s Look at the Future

More information

The Affordable Care Act and What it means To Us By Dr. Ron Short, DC, MCS-P

The Affordable Care Act and What it means To Us By Dr. Ron Short, DC, MCS-P The Affordable Care Act and What it means To Us By Dr. Ron Short, DC, MCS-P Medicare Enrollment Changes On September 23, 2010 CMS published some proposed rules in the Federal Register for comment. The

More information

Banner Health Network Pioneer ACO - Physician Toolkit

Banner Health Network Pioneer ACO - Physician Toolkit & The Banner Health Network, an AIP and Banner Health partnership, present the Banner Health Network Pioneer ACO - Physician Toolkit This BHN Pioneer ACO Physician Toolkit has been developed to provide

More information

6 Critical Impact Factors of Health Reform on Revenue Cycle Management Pyramid Healthcare Solutions Thought Leadership Series

6 Critical Impact Factors of Health Reform on Revenue Cycle Management Pyramid Healthcare Solutions Thought Leadership Series 6 Critical Impact Factors of Health Reform on Revenue Cycle Management Pyramid Healthcare Solutions Thought Leadership Series The healthcare industry is undergoing significant change in the face of the

More information

Enterprise Analytics Strategic Planning

Enterprise Analytics Strategic Planning Enterprise Analytics Strategic Planning June 5, 2013 1 "The first question a data driven organization needs to ask itself is not "what do we think?" but rather "what do we know? Big Data: The Management

More information

Accountable Care Organizations and Market Power Issues

Accountable Care Organizations and Market Power Issues Accountable Care Organizations and Market Power Issues October, 2010 Introduction Accountable care organizations (ACOs) have received significant attention since passage of the Patient Protection and Affordable

More information

Commercially Reasonable - Whose Responsibility is it?

Commercially Reasonable - Whose Responsibility is it? OCTOBER 2012 healthcare financial management FEATURE STORY Jen Johnson Commercially Reasonable - Whose Responsibility is it? AT A GLANCE Key factors that a hospital finance leader should focus on when

More information

Finalized Changes to the Medicare Shared Savings Program

Finalized Changes to the Medicare Shared Savings Program Finalized Changes to the Medicare Shared Savings Program Background: On June 4, 2015, the Centers for Medicare and Medicaid (CMS) issued a final rule that updates implementing regulations for the Medicare

More information

In early April, the Center for Medicare and Medicaid Services (CMS) issued

In early April, the Center for Medicare and Medicaid Services (CMS) issued April 26, 2011 If you have any questions regarding the matters discussed in this memorandum, please contact the following attorneys or call your regular Skadden contact. John T. Bentivoglio 202.371.7560

More information

DRAFT NCMS POLICY (v. 7) Accountable Care Organizations

DRAFT NCMS POLICY (v. 7) Accountable Care Organizations DRAFT NCMS POLICY (v. 7) Accountable Care Organizations Background: Accountable Care Organizations (ACOs) are an emerging health care delivery model comprised of groups of providers that join together

More information

Application & Implementation of ACO Waivers and Ongoing Compliance Issues

Application & Implementation of ACO Waivers and Ongoing Compliance Issues Application & Implementation of ACO Waivers and Ongoing Compliance Issues Presenter Todd A. Zigrang MBA, MHA, FACHE, ASA HEALTH CAPITAL CONSULTANTS Thursday, August 13, 2015 1:30 p.m. Hilton St. Louis,

More information

Cms Finally speaks: organization (ACO) proposed regulations and WhaT They mean For anesthesiologists

Cms Finally speaks: organization (ACO) proposed regulations and WhaT They mean For anesthesiologists ANESTHESIA BUSINESS CONSULTANTS SUMMER 2011 VOLUME 16, ISSUE 2 Cms Finally speaks: The accountable Care organization (ACO) proposed regulations and WhaT They mean For anesthesiologists Since the passage

More information

Accountable Care Organizations

Accountable Care Organizations Building a Healthy ACO Compliance Program: Good Help ACO s Experience in Building Healthy Communities While Leveraging Existing Resources to Establish a Healthy and Effective ACO Compliance Program. Mary

More information

Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program

Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program M A Y 2 0 1 1 Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS), the Department

More information

Medical Group Development, PHOs, MSOs, Nonprofit Medical Foundations and Fully Integrated Delivery Systems

Medical Group Development, PHOs, MSOs, Nonprofit Medical Foundations and Fully Integrated Delivery Systems Medical Group Development, PHOs, MSOs, Nonprofit Medical Foundations and Fully Integrated Delivery Systems Medical Group Formation Medical Group Foundation Physician Hospital Organizations (PHOs) Management

More information

Georgia Society for Healthcare Materials Management. The status of ACO s in the market and how they impact materials management.

Georgia Society for Healthcare Materials Management. The status of ACO s in the market and how they impact materials management. Georgia Society for Healthcare Materials Management The status of ACO s in the market and how they impact materials management October 25, 2013 A Highly Volatile And Complex Industry Key Trends Impacting

More information

ACOs: Fraud & Abuse Waivers and Analysis

ACOs: Fraud & Abuse Waivers and Analysis ACOs: Fraud & Abuse Waivers and Analysis Robert G. Homchick and Sarah Fallows Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

Making the Transition into Risk-Based Payment Why Children s Hospitals Need to Accept Value-Based Care Strategies

Making the Transition into Risk-Based Payment Why Children s Hospitals Need to Accept Value-Based Care Strategies Making the Transition into Risk-Based Payment Why Children s Hospitals Need to Accept Value-Based Care Strategies Substantial changes within the Medicaid marketplace are driving U.S. children s hospitals

More information

Pay For Performance and Medicare Compliance; The Irresistible Force Meets the Immovable Object

Pay For Performance and Medicare Compliance; The Irresistible Force Meets the Immovable Object APRIL 2007 Pay For Performance and Medicare Compliance; The Irresistible Force Meets the Immovable Object Mark R. Fitzgerald Powers Pyles Sutter & Verville PC, Washington, DC Since the Institute of Medicine

More information

2019 Healthcare That Works for All

2019 Healthcare That Works for All 2019 Healthcare That Works for All This paper is one of a series describing what a decade of successful change in healthcare could look like in 2019. Each paper focuses on one aspect of healthcare. To

More information

Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View

Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View Troy Barsky, Esq. Jennifer Williams, Esq. Crowell & Moring Daniel Murphy, Esq. Bradley Arant Boult & Cummings

More information

Quality Accountable Care Population Health: The Journey Continues

Quality Accountable Care Population Health: The Journey Continues Quality Accountable Care Population Health: The Journey Continues Health Insights April 10, 2014 Doug Hastings 2001 Institute of Medicine 2 An Agenda For Crossing The Chasm Between the health care we have

More information

Managing and Coordinating Non-Acute Care in an ACO Environment

Managing and Coordinating Non-Acute Care in an ACO Environment Managing and Coordinating Non-Acute Care in an ACO Environment By Glen Roebuck, Vice President of Business Development, Health Dimensions Group Hospital and health care systems across the country are engaging

More information

IU Health Quality Partners

IU Health Quality Partners FREQUENTLY ASKED QUESTIONS 1) What is IU Health Quality Partners? It is a clinically integrated provider group; it is not a contracted health insurance plan network where physicians receive a set fee for

More information

Medicare Value Partners

Medicare Value Partners Medicare Value Partners Medicare Shared Savings ACO Program Frequently Asked Questions (FAQ) Q: What exactly is a Medicare Shared Savings Program ACO? A: Medicare Shared Savings Program accountable care

More information

Brief Course. Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs

Brief Course. Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs Accountable Care Organization (ACO) 101 Brief Course Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs What is an ACO? ACO refers to a legal entity composed of a group of providers that assume

More information

Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices

Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices Martin Bienstock, Esq. Wilson Elser Martin.Bienstock@WilsonElser.com The New York Times Take... For the first

More information