Joseph Rugg's Health Law Blog

A lot happened this morning in the area of ACOs. 

Whether any of the hundreds of pages of paper will be sufficient guidance to meaningfully assist healthcare providers and their advisors on how to proceed, only time will tell. 

• CMS published its proposed regulations implementing Section 3022 of the Health Care Reform Act relating to payments to providers and suppliers  participating in Accountable Care Organizations (ACOs).
• The OIG published its notice relating to the application (and waiver)  of certain fraud and abuse laws in connection with ACOs.
• The FTC and DOJ published their proposed statement of antitrust enforcement policy relating to ACOs.

These are only proposed at this stage, and there is time to comment  on the practicalities and difficulties of the proposals.

I suspect that we are going to see things start moving fast.  There will be fear of being left behind.

So, it is time for physicians (if they haven’t already — which they should have been) to get educated about ACOs and what they mean to their practice of medicine.   ACOs can provide a method for physician practices to remain independent.  ACOs can also promote the consolidation of physician practices into larger single-specialty and multi-specialty groups.  ACOs can also lead to the employment of physicians by hospitals and other large integrated healthcare delivery systems. 

Standing still is an option for only the very short term.

Akerman Senterfitt’s brief summary of the proposed regulations can be found here.