The Centers for Medicare and Medicaid Services (CMS) proposed rules for Accountable Care Organizations (ACOs) under the Medicare Shared Savings Program (MSSP) includes a number of requirements related to the structure and governance of ACOs, the shared savings program, ACO participation and provider eligibility, antitrust concerns, health information and privacy, and controlling fraud and abuse. This article discusses some of the odds and ends included in the proposed rules that are more nuanced, but nevertheless important.
CMS also requested public comment on whether other provider types and suppliers should own or participate in ACOs. CMS will consider whether FQHCs and RHCs should be able to form an ACO. CMS will also consider whether skilled nursing facilities, long-term acute care hospitals, and other types of providers and suppliers that are not specifically designated as eligible participants in the MSSP may form and/or participate in an ACO.