CMS Issues Final Regs -- Rule accompanied by feedback from the OIG, FTC, DOJ and IRS

CMS Issues Final Regs -- Rule accompanied by feedback from the OIG, FTC, DOJ and IRS


On October 20, 2011, CMS issued final regulations on Accountable Care Organizations (ACOs). The final rule may be viewed by clicking here. This final rule was accompanied by:


  • A final policy statement from the Federal Trade Commission and Department of Justice on antitrust enforcement relating to ACOs participating in the Medicare Shared Savings Program (MSSP).
  • A fact sheet from the IRS confirming that IRS Notice 2011-10 continues to state the position of the IRS as to ACOs and the MSSP.


The Health Law Section ACO Task Force is committed to providing Section members with a timely analysis of these important rules.


On November 3, the Section provided a webinar, "The ACOs Are Coming: What You Must Know About the Accountable Care Organizations Final Rules." Click here to pre-order a recording of the program.


The Health Law Section also offered a two-part webinar series took an in-depth look at how the Centers for Medicare and Medicaid Services have changed the Medicare Shared Savings Program (MSSP) through the publication of final regulations.

Part 1: Quality of Care, Antifraud, and Antitrust

Part 2: Assignment of Beneficiaries, Risk, Structure and Governance, and Tax Issues


We invite you to take advantage of all that the ACO Task Force has to offer. Membership in this task force is available to all Section members at no additional cost. You can access the ACO Task Force webpage by clicking here. If you are interested in joining our ACO Task Force please click here or contact Simeon Carson at