In this article, "Delicate Balance: Waiver of Fraud and Abuse Laws and Implementation of Program Integrity Requirements for the Medicare Shared Savings Program," published in BNA's Health Care Fraud Report on November 30, 2011, Mintz Levin attorneys Thomas S. Crane, Brian P. Dunphy and Karen S. Lovitch describe the recently released "Waiver Rule," and the five waivers detailed therein. While these waivers are broader and more flexible than previous ones, ACOs and ACO participants must still comply with strict program integrity requirements implemented by CMS as part of the "Final Rule."
To read the article in full, click here.