The Final Accountable Care Organization Regulations: One Part Flexibility, Two Parts Complexity


Firm Event

Presented by: Gray Plant Mooty

CMS just released final regulations implementing the 2010 Affordable Care Act Accountable Care Organization (ACO) initiative. ACOs are aimed at encouraging providers to collaborate through payment of shared Medicare savings. In its initial form, the ACO program was considered overly complex and received much industry criticism. In response, CMS has taken steps in the final regulations to make ACOs more attractive. However, in spite of some new flexibility, the ACO program remains very technical and presents compliance challenges as well as uncertain financial returns for providers. Providers do not have much time to make up their minds about ACOs as CMS begins to accept applications on January 1 with the ACO program starting on April 1.

Please join Gray Plant Mooty’s Health Law Team for a roundtable breakfast to discuss the new ACO regulations and their implications for providers. Topics to be covered include:

  • New flexibility in governance, eligibility and participation requirements;
  • Process for obtaining shared savings, including opportunity to participate without taking risk for potential ACO losses during initial three year term;
  • Reduced quality and performance reporting obligations along with prospective assignment of beneficiaries to aid ACOs in more effectively coordinating care;
  • CMS oversight of ACO marketing and other beneficiary protections;
  • Expanded waivers of the Stark Law, Anti-kickback Statute, Civil Monetary Penalties “gainsharing” prohibition along with more flexible antitrust policy.

Jesse Berg, Catie Bitzan, Tim Johnson, and Jeremy Johnson Members of Gray Plant Mooty’s Health Law Team

7:30 – 8:00 a.m. Breakfast/Registration
8:00 – 9:30 a.m. Program

Kindly RSVP by November 28, 2011, and indicate whether you intend to participate in person or by webinar. Instructions to join the webinar will follow.

RSVP by email to or by phone to 612.632.3170

There is no registration fee for this program.
Parking will be validated for the Marquette/IDS Ramp.
Enter the ramp on Marquette Avenue between 7th and 8th Streets South.

7:30 a.m.

Gray Plant Mooty, 500 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402


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