There is much happening in the whirlwind of health reform, and the granular transformation enabled by the passage of the Patient Protection and Affordable Care Act (PPACA). The theater in Washington notwithstanding and well as the growing storm of legal challenges to the insurance mandate leave much of the implementation path somewhat clouded.
Yet the ‘roll up your sleeves and make a difference’ crowd rather than whine and obstruct, are rather busy and focused on the granular transformational opportunites written into PPACA.
Three recent posts are well worth singling out, they include:
Jaan Didorov, MD, and publisher of the Disease Management Blog, on ‘No Faux ACO’s Here!’ A play witty on CMS Administrator Don Berwick’s earlier industry admonition, as well as ‘How To Get Independent Physicians Into an Accountable Care Organization‘, offers select insights and commentary of a mature IDN, absent the staff (or employed group) model DNA typically associated with Mayo, and Kaiser Permanente ACO strains, but more of a private/voluntary medical staff model culture, over at Advocate Health Partners.
Also, check out ACOs and the Shared Savings Program; Some Common Misconceptions, by Reed Tinsley, CPA.
We welcome your comments and engagement!
J. Peter Rich is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Los Angeles office. He co-chairs the Firm’s Insurance / Payors Affinity Group.
The FTC, CMS and OIG hosted a public workshop on October 5, 2010, featuring panel and listening discussions on regulatory issues surrounding how the development and operation of accountable care organizations would be affected by the use of waivers, safe harbors and other exceptions to various fraud and abuse laws.
The U.S. Federal Trade Commission, the Centers for Medicare & Medicaid Services (CMS) and the Office of the Inspector General (OIG) hosted a public workshop October 5, 2010. A previous newsletter summarized the morning sessions of the workshop, which concerned antitrust issues. This newsletter focuses on the afternoon sessions of the workshop, which featured a panel discussion and listening session regarding how the secretary of the U.S. Department of Health and Human Services (HHS) may encourage the creation and development of accountable care organizations (ACOs) by using the position’s waiver authority or creating new exceptions and safe harbors related to the Anti-Kickback Law, the Stark Law and the Civil Monetary Penalty Law.
Workshop participants shared a range of viewpoints concerning how the formation and operation of ACOs would be affected by the use of waivers, safe harbors and other exceptions to various fraud and abuse laws. The OIG and HHS did not provide any details as to precisely what forms such waivers, safe harbors and exceptions might take, instead, they merely received input from participant-stakeholders regarding the range of views and possible approaches that should be considered when structuring the ACO model.
For complete blog post, click here.
Welcome to ‘ACO Watch‘. With the first official ACO to be so anointed shortly by the regulatory apparatus in Washington, DC and/or Baltimore, we thought there might be a place to monitor, track, educate, inform and perhaps even entertain as we witness the ramp-up for the ACO indusry – staggered as it may be.
Opening post is pasted below:
October 5th, 2010 § 1 Comment
With the March passage of the ‘Patient Protection and Affordable Care Act (PPACA), the ‘follow the money’ floodgates are once again opening for hospitals, physicians, integrated delivery systems, health plans, and consultants. This time, instead of migrating ‘HMO lite’ (neither staff nor group model) platforms into mainstream medicine via IPAs, we’re now talking about their ‘new and improved’ successors broadly cast as ‘Accountable Care Organizations aka ‘ACOs’.
Some call it ‘managed care 2.0′, while the more cynical among us envision it as the full employment act for consultants, and health care lawyers, shopping a not ready for prime time, if not fundamentally flawed ‘business model’.
Given the high level of interest in these ostensible quality promoting, while cost restraining entities, the staggered implementation timeline in general, the ACO January 1, 2012 fuse in particular, and the broad brush framework intentionally reflected in PPACA, we thought it a good idea to keep a pulse on the ramp up to the highly anticipated ‘go live’ date.
We welcome your interest and contributions to this conversation.
Please check out ACO Watch or updates, guest posts, news, conferences and webinars that may be useful to you!