In the months leading up to Election Day 2012, the pace of health reform implementation slowed considerably as the Obama administration held off on releasing regulations to avoid pre-election controversy. With the 2012 elections now in the books, health reform has scored two major victories: the re-election of President Barack Obama
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Medicare ACOs: Financial and Clinical Integration
By Doug Hastings on
Back in 1996, the Federal Trade Commission and Department of Justice, in providing antitrust guidance for multi-provider networks, considered financial integration and clinical integration as separate pathways for such networks to avoid per se violations of the antitrust laws and, instead, to be treated under the rule of reason, allowing for an assessment of their…
Revisiting the Medicare Shared Savings Program: An Interagency Effort to Promote Accountable Care
By Epstein Becker Green on
Posted in Agency Information
by Ross K. Friedberg, Shawn M. Gilman, Mark E. Lutes, David E. Matyas, René Y. Quashie, Serra J. Schlanger, Carrie Valiant, Dale C. Van Demark, and Lesley R. Yeung
On October 20, 2011, the Centers for Medicare & Medicaid Services ("CMS") released its final rule ("Final Rule")…
CMS Innovation Center Announces Four Models in Bundled Payments for Care Improvement Initiative
By Epstein Becker Green on
Posted in Cost of Health Care
by Lesley R. Yeung, Shawn M. Gilman, and Serra J. Schlanger
On August 23, 2011, the Centers for Medicare & Medicaid Services (“CMS”) Innovation Center announced a new initiative to encourage health care providers to better coordinate patient care. The Bundled Payments for Care Improvement Initiative (“Bundled Payments Initiative”) seeks to align the…
OPM RFI Regarding Multi-State/National Insurance Plans
By Epstein Becker Green on
Posted in Cost of Health Care
by Lynn Shapiro Snyder, Shawn M. Gilman, Adam C. Solander, and Constance A. Wilkinson
On June 16, 2011, the Office of Personnel Management (“OPM”) released the Request for Information (“RFI”) regarding Section 1334 of the Affordable Care Act, which requires OPM to contract with health insurers to offer multi-state qualified health plans (“MSQHPs”).
Overview of Methodology for Determining PSA Shares for Accountable Care Organizations Participating in the Medicare Shared Savings Program
By Epstein Becker Green on
Posted in Innovations in Health Care Delivery
by Patricia M. Wagner and Ross K. Friedberg
Among the criteria that the “Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program” (“Proposed Statement”) uses to evaluate an accountable care organization’s (“ACO’s”) risk of an antitrust challenge is the ACO applicant’s “market share” within each of its…
Overview of the FTC/DOJ Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program
By Epstein Becker Green on
Posted in Innovations in Health Care Delivery
by Patricia M. Wagner and Ross K. Friedberg
On April 19, 2011, the “Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program” (“Proposed Statement”) was published in the Federal Register. As noted in the Proposed Statement, the antitrust enforcement agencies (the Department of Justice Antitrust Division and…
Five Wishes for the Medicare Shared Savings Program Regulations
By Doug Hastings on
As the health care world awaits the Medicare Shared Savings Program regulations expected to be issued soon by CMS, below is a wish list for key attributes that I hope the regulations evidence:
1. Flexibility.
"Transforming health care everywhere starts with transforming it somewhere." I hope that CMS takes Atul Gawande’s advice and …