America’s Health Insurance Plans (AHIP), the national association of health plans, has issued this issue brief on accountable care organizations (ACOs). Predictably, AHIP highlights the potential negative consequences of establishing ACOs by discussing the potential local and regional market dominance of hospitals, health systems, physician groups and other health care provider organizations that might become ACOs. The issue brief also details the numerous antitrust issues that ACOs must overcome. Of course, the ACO model is partially designed to bypass health insurance plans as purchasers/payors by allowing direct relationships between local hospitals, physicians and other providers (and the federal government through Medicare) to share risks and cost savings through population-level quality improvement.