Health Care Reform Advisory: ACO Fraud & Abuse Provisions
5/6/2011
By Brian P. Dunphy and Ellyn L. Sternfield
Late last month, the Centers for Medicare & Medicaid Services (CMS) released proposed regulations addressing the operation and structure of Accountable Care Organizations (ACOs) and creating the Medicare Shared Savings Program. The arrangements that may be necessary or desirable to form ACOs and to participate in the Program raise new fraud and abuse concerns. Providers will need to understand and address the fraud and abuse provisions of the Proposed Rule in order to assure initial and ongoing compliance. The deadline for submitting comments on the proposed regulations is June 6, 2011. Mintz Levin is providing a series of Health Care Reform alerts regarding provisions of the proposed regulations. This advisory addresses the fraud and abuse implications of the proposed regulations.
