• The Proposed Regulations on Accountable Care Organizations and the Role of Long Term Care, Home Care, and Other Providers Across the  Continuum: A Seat at the Table, or “Poor Cousin” to Hospitals and Physician Groups?
  • May 10, 2011 | Authors: Brian T. McGovern; Tracy E. Miller
  • Law Firm: Cadwalader, Wickersham & Taft LLP - New York Office
  • Enacted by Congress in March 2010, the Patient Protection and Affordable Care Act (“PPACA”) required the Federal Centers for Medicare and Medicaid Services (“CMS”) to establish a Shared Savings Program, under which Accountable Care Organizations (“ACOs”) would assume responsibility for the cost and quality of care for Medicare fee-for-service (“FFS”) beneficiaries and share in the savings achieved in accord with financial and clinical benchmarks set by CMS. In our November 30, 2010, Clients & Friends Memo, “National Health Care Reform Promotes Accountable Care Organizations”, we discussed some of the legal and regulatory issues surrounding ACOs posed by PPACA. We also noted that many key issues related to ACO formation, governance, operation, and financial incentives would be addressed in the regulations.