With the March 2010 passage of the ‘Patient Protection and Affordable Care Act (PPACA), the ‘follow the money’ floodgates are once again opening for hospitals, physicians, integrated delivery systems, health plans, and consultants. This time, instead of migrating ‘HMO lite’ (neither staff nor group model) platforms into mainstream medicine via IPAs, or MeSH model JV’s, we’re now talking about their ‘new and improved’ successors broadly cast as ‘Accountable Care Organizations aka ‘ACOs’.
Some call it ‘managed care 2.0’, while the more cynical among us envision it as the full employment act for consultants, and health care lawyers, shopping a not ready for prime time, if not fundamentally flawed ‘business model’.
Given the high level of interest in these ostensible quality promoting, while cost restraining entities, the staggered implementation timeline in general, the ACO January 1, 2012 fuse in particular, and the broad brush framework intentionally reflected in PPACA, we thought it a good idea to keep a pulse on the ramp up to the highly anticipated ‘go live’ date.
For those who may be interested in participating in this session but unable to attend, apparently the workshop closed early due to considerable interest, you may opt for an online webinar beginning at 9AM ET/6AM PT. You may register direct here.
For more details including the agenda, see write up courtesy of McDermott, Will & Emory.
The workshop will feature panel discussions and a listening session on various legal issues related to ACOs, including antitrust, physician self-referral, anti-kickback and civil monetary penalty laws. In particular, the FTC, CMS and OIG wish to receive industry feedback on the following issues:
- How various ACO structures in different health care markets could affect the cost and quality of health care delivered to privately insured consumers and Medicare and Medicaid beneficiaries
- Whether (and if so, how) the requirements of the antitrust, physician self-referral, anti-kickback and civil monetary penalty laws should be addressed in the regulations under development for the Medicare Shared Savings Program
- To what extent, if at all, any safe harbors, exceptions, exemptions or waivers from the aforementioned laws may be warranted