Tag Archives: Medicare Shared Savings Program

Proposed Overhaul to the Medicare Shared Savings Program Would Mean More Risk for ACOs

hospital staff
On August 9, 2018, CMS introduced a proposed rule that would substantially overhaul the Medicare Shared Savings Program (MSSP), requiring Accountable Care Organizations (ACOs) that participate in the MSSP to accept some downside risk and tightening other requirements to increase program integrity. At the same time, the proposed rule would allow ACOs increased flexibility in … Continue reading this entry

IRS Denies Exempt Status for Non-MSSP Accountable Care Organizations

In April, the IRS released a private letter ruling denying section 501(c)(3) status to an accountable care organization (“ACO”) that contracted with third-party payers outside of the Medicare Shared Savings Program (“MSSP”). I.R.S. Priv. Ltr. Rul. 2016-15-022 (Jan. 15, 2016). The ACO was formed by a non-profit, tax-exempt health system to coordinate a clinically integrated … Continue reading this entry

CMS Issues Final Rule on ACOs Participating in the Medicare Shared Savings Program

The Centers for Medicare & Medicaid Services (“CMS”) issued a final rule (the “Final Rule”) for accountable care organizations (“ACOs”) participating in the Medicare Shared Savings Program (“MSSP”) on June 6, 2016. In the Final Rule, CMS reflects its continuing efforts to modify alternative payment programs to make them more workable while also moving toward … Continue reading this entry

CMS Proposes Additional Changes to MSSP Regulations

Regulatory-Developments
The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule modifying the Medicare Shared Savings Program (MSSP) regulations (the “Rule”). Among other changes, the Rule proposes (a) to modify the method in which cost benchmarks for MSSP-participating Accountable Care Organizations (ACOs) are updated both during a three-year agreement period and upon renewal, and … Continue reading this entry

2016 Will Be the Year of Telemedicine and ACOs

If 2015 was the year that brought telemedicine directly to consumers, 2016 will be the year of telemedicine and Accountable Care Organizations (ACOs). ACOs are expected to increase the use of telemedicine technologies as a way to improve patient quality, achieve greater cost savings, and meet Center for Medicare & Medicaid Services’ (CMS) patient threshold.… Continue reading this entry

Top Three Reasons ACOs Should Use Telehealth and Telemedicine

Accountable Care Organizations (ACOs) can share costs of telehealth and remote patient monitoring services among their hospitals, providers/suppliers, and other ACO participants, according to federal regulations under the Medicare Shared Savings Program (MSSP) fraud and abuse waivers. In protecting these arrangements, CMS and OIG recognize how telehealth technologies and innovative care processes can help reduce … Continue reading this entry

OIG and CMS Issue Rule: Finalizing Fraud and Abuse Waivers for MSSP ACOs

The Centers for Medicare and Medicaid Services (CMS) and the Office of Inspector General (OIG) of the Department of Health and Human Services just issued a final rule setting forth waivers of specified fraud and abuse laws applicable to the Medicare Shared Savings Program (MSSP). The final rule replaces the Interim Final Rule (IFC) with comment … Continue reading this entry

2014 Medicare ACO Results Released: CMS Asserts Success but Few ACOs Receive Payments

The Centers for Medicare and Medicaid Services (CMS) released, on August 25, 2015, the quality and financial performance results for Medicare Accountable Care Organizations for 2014. CMS touted that Medicare ACOs continued to improve care while slowing growth in health care costs.… Continue reading this entry

MSSP Final Rule Adopts All Proposed Additional Program Requirements and Beneficiary Protections Provisions

This is the sixth post in Health Care Law Today’s series on the final rule. This post addresses additional program requirements and beneficiary protections. The Medicare Shared Savings Program (“MSSP”) final rule published on June 4, 2015 finalized all proposed additional program requirements and beneficiary protections outlined in the December 2014 proposed rule. The specific … Continue reading this entry

MSSP Final Rule Provides Modification to Shared Savings Financial Arrangement

This is the fifth post in Health Care Law Today’s series on the final rule. The final Medicare Shared Savings Program (“MSSP”) rule released on June 4, 2015, contains a number of modifications to the financial arrangement contained in the existing regulations. The modifications are designed to encourage ACOs to participate or continue participating in the … Continue reading this entry

Beneficiary Assignment Under the MSSP Final Rule

This is the fourth post in Health Care Law Today’s series on the final rule. This post addresses how CMS assigns beneficiaries to an ACO participating in the MSSP. In the MSSP ACO Final Rule, CMS finalized new regulations that govern the assignment of Medicare fee-for-service beneficiaries to an ACO participating in the MSSP.… Continue reading this entry

Final Rule Will Give ACOs Participating in MSSP Access to More Data for More Beneficiaries

American Hospital Association Recommends Revisions to Medicare ACO Models
This is the third post in Health Care Law Today’s series on the final rule. This post addresses changes to sharing of beneficiary identifiable data. In its December 8, 2014 proposed rule revising the Medicare Shared Savings Program (“MSSP”), CMS proposed several changes concerning how it would share beneficiary identifiable data with Accountable Care Organizations (“ACOs”). … Continue reading this entry

MSSP Final Rule ACO Eligibility Requirements, Application and Renewal Process

This is the second post in Health Care Law Today’s series on the final rule. This post addresses Eligibility Requirements, and the Application and the Renewal Process. ACO Eligibility Requirements Under the Medicare Shared Savings Program (“MSSP”) ACO Final Rule, CMS finalized new regulations that will change ACO eligibility requirements. The final rule will include … Continue reading this entry

CMS Releases Final Rule on Medicare Shared Savings Program

This is the first post in Health Care Law Today’s Series on the final rule. The Centers for Medicare and Medicaid Services (“CMS”) released a final rule, on June 4, 2015, addressing changes to its Medicare Shared Savings Program (“MSSP”) Accountable Care Organization (“ACO”) Regulations. The final rule follows a proposed rule released on December … Continue reading this entry

CMS Announces Next Generation ACO Model

CMS announced a new ACO payment initiative on March 10, 2015, the Next Generation ACO Model, designed for entities experienced in coordinating care for populations of patients. The announcement reflects CMS’ commitment to exploring different Medicare payment arrangements that encourage providers to assume higher levels of financial risk and reward while delivering quality care. The Next Generation … Continue reading this entry

CMS Proposes Financial Revisions to MSSP to Encourage Continued and Expanded Participation

Preparing for the Conversion to ICD-10
This is the sixth post in Health Care Law Today’s series on the proposed rule modifying the Medicare Shared Savings Program (“MSSP”). The proposed rule was published in the Federal Register on December 8, 2014 and parties have 60 days to offer comments. Click here to read earlier posts about the rule. This post addresses proposed … Continue reading this entry

Beneficiary Assignment in the Proposed Revised Medicare Shared Savings Program Regulations

Health Care Law Today is issuing a series of blog posts about the Centers for Medicare and Medicaid Services’ (CMS) proposed rule to revise the Medicare Shared Savings Program (MSSP) Accountable Care Organization (ACO) regulations (the Proposed Rule). This is the fifth post in Health Care Law Today’s series on the Proposed Rule. Click here to read … Continue reading this entry

CMS Proposes Sharing More Data With ACOs Participating in the Medicare Shared Savings Program

Preparing for the Conversion to ICD-10
This is the fourth post in Health Care Law Today’s series on the proposed rule revising the Medicare Shared Savings Program. The rule was published in the Federal Register on December 8, 2014 and parties have 60 days to offer comments.  Click here to read earlier posts about the rule. This post addresses the changes that … Continue reading this entry

MSSP Proposed Rule Seeks to Enhance ACO Transparency and Patient Engagement

Regulatory-Developments
This is the third post in Health Care Law Today’s series on the ACO proposed rule. Click here to read the first post and here to read the second post. Additional Program Requirements and Beneficiary Protections Under the Medicare Shared Savings Program (“MSSP”) ACO proposed rule, CMS has proposed additional program requirements, beneficiary protections and … Continue reading this entry

CMS Invites Comment on Availability of Waivers for ACOs That Particularly Affect Post-Acute Care

Preparing for the Conversion to ICD-10
This is the second post in Health Care Law Today’s series on the proposed rule. Click here to read the first post. Solutions and opportunities may be on the horizon for post-acute providers (“PAPs”) and hospitals participating (or thinking of participating) in ACOs that have reservations about taking on additional downside cost risk associated with the … Continue reading this entry

CMS Releases Proposed Revised Medicare Shared Savings Program Regulations

This is the first post in Health Care Law Today’s series on the proposed rule. The Centers for Medicare and Medicaid Services released, on December 1, 2014, a proposed rule to revise the Medicare Shared Savings Program (“MSSP”) Accountable Care Organization (“ACO”) Regulations. The proposed rule is expected to be published in the Federal Register on December … Continue reading this entry

CMS Unveils New Plan to Provide Infrastructure Capital to ACOs

Regulatory-Developments
The Center for Medicare & Medicaid Innovation introduced the ACO Investment Model, on October 15, 2014, through which CMS will provide newly-formed ACOs in rural and underserved areas access to capital necessary for investment in the infrastructure necessary to successfully implement care management and assist existing ACOs to prepare to assume greater financial risk. Through the … Continue reading this entry

American Hospital Association Recommends Revisions to Medicare ACO Models

The American Hospital Association (AHA) submitted a letter to the Centers for Medicare and Medicaid Services (CMS) on April 17, 2014, recommending modifications to the Medicare Shared Savings Program (MSSP) and the Pioneer ACO program to make both of these programs more attractive to hospitals and health systems. The AHA letter begins by noting that … Continue reading this entry