The law firm Davis Wright Tremaine has been posting a series of publicly downloadable “advisories” on its website, analyzing the Centers for Medicare and Medicaid Services proposed rule on Medicare Shared Savings Accountable Care Organizations (ACOs). To date, the advisories have provided an overview of the proposed rule (April 5), reviewed the proposed antitrust policies involved (April 6), analyzed the legal structures and governance requirements (April 11), reviewed the fraud and abuse waivers (April 15), examined the quality measures required for reporting (April 18), explained the Medicare beneficiary assignment process (May 2), and reviewed the Internal Revenue Service guidance for tax-exempt organizations seeking to become ACOs (May 9).
Ignatius Bau 