HLS Comments on ACO Medicare Shared Savings Program

HLS Comments on ACO Medicare Shared Savings Program

The Health Law Section submitted comments on the Interim Final Rule issued jointly by the Centers for Medicare & Medicaid Services (“CMS”) and the Department of Health and Human Services’ Office of Inspector General (“OIG”) establishing waivers of the application of the Physician Self-Referral Law (also known as the Stark law), the federal Anti-Kickback Statute, and certain civil monetary penalties law provisions to specified arrangements involving accountable care organizations (“ACOs”) as authorized by Section 1899(f) of the Social Security Act as necessary to implement the Medicare Shared Savings Program (the “MSSP”). The comments were prepared by the Section’s ACO Task Force, then approved by the Section’s Council and submitted to CMS on December 28, 2011.

A special thank you to all of our volunteer members. Contributors to these comments were Claire Turcotte, Stephanie Willis, Catherine Greaves, John Steiner, Barry Liss, Christina Torossian, Matt Jenkins, Carol Bowen, David Crapo, Kelvin Ziegler and Amy Fehn, who chaired the Task Force’s working group on these comments. In addition, William W. Horton, Co-Chair of the Section’s Health Law and Policy Review Coordination Committee, served as reviewer of the Task Force’s work and participated in the preparation of the final comments.

To view the final comments, please click here.

If you are interested in getting involved in providing feedback regarding health law-related policy decisions, please contact Simeon Carson, Associate Director, at simeon.carson@americanbar.org.