HealthLaw HotSpot - A Look at Alternative Reimbursement Models in Value-Based Care
Jones Day Talks Health Care: The Eliminating Kickbacks in Recovery Act
Value-based health care: fraud & abuse laws
Tax Developments Affecting Health Care Organizations and Investor-Owned Hospital Companies
On July 14, 2025, the Centers for Medicare & Medicaid Services (“CMS”) released the proposed rule for the Calendar Year (“CY”) 2026 Medicare Physician Fee Schedule (“PFS”), formally titled CMS-1832-P....more
Decisions, decisions, decisions. The Centers for Medicare & Medicaid Services (CMS) under the Trump Administration will have its hands full making decisions about Center for Medicare and Medicaid Innovation (CMMI) models...more
New policies tucked into the Centers for Medicare and Medicaid Services’ (CMS) 2025 Medicare Physician Fee Schedule Rule (Final Rule) will likely spur increased Accountable Care Organization (ACO) participation in the...more
Within its proposed CY 2025 Physician Fee Schedule (PFS) rule (the Proposed Rule), CMS is proposing to implement new payment policies intended to advance health equity and support whole-person care. CMS expects these new...more
On June 24, 2024, the Centers for Medicare & Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) at the Department of Health and Human Services (HHS) issued the 21st...more
In coordination with the Centers for Medicare & Medicaid Services (CMS), the Department of Health and Human Services (HHS) and Office of the National Coordinator for Health Information Technology (ONC) proposed a...more
The Centers for Medicare and Medicaid (CMS) announced on August 24 that the Medicare Shared Savings Program (the MSSP) had the second-highest annual savings accrued for Medicare since the program’s initial launch in 2012...more
This August, the Centers for Medicare and Medicaid Services (CMS) announced multiple changes (to take effective in performance year 2024) to one of its alternative payment models, the Accountable Care Organization Realizing...more
The Centers for Medicare & Medicaid Services (CMS) announced a new primary care model—the Making Care Primary (MCP) Model—geared towards smaller, independent primary care practices and organizations that want to participate...more
Holland & Knight Health Dose is an in-depth weekly dose of legislative and regulatory insights to keep stakeholders abreast of happenings in Washington, D.C., impacting the health sector. This week's topics include: ...more
On November 1, 2022, the Centers for Medicare & Medicaid Services (CMS) issued changes to the Medicare Shared Savings Program to advance CMS’ broader strategy of growth, alignment, and equity. To improve the overall...more
The Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (PFS) Final Rule on Nov. 1, 2022, which impacts Medicare Part B payments starting on Jan. 1, 2023....more
As part of the CY 2023 Physician Fee Schedule proposed rule (the Proposed Rule) released on July 7, 2022, CMS has proposed significant changes to the Medicare Shared Savings Program (MSSP). The agency’s press release...more
On February 24, 2022, the Centers for Medicare & Medicaid Services (CMS) announced that it had redesigned the Global and Professional Direct Contracting Model for 2023. The Center for Medicare and Medicaid Innovation...more
On February 24, 2022, the Centers for Medicare and Medicaid Services (CMS) Innovation Center announced a Request for Applications (RFA) for the Accountable Care Organization (ACO) Realizing Equity, Access, and Community...more
On February 24, 2022, the Centers for Medicare & Medicaid Services (CMS) announced its redesign of the Global and Professional Direct Contracting Model (GPDC), which now will be called the Accountable Care Organization (ACO)...more
The Situation: As health care providers transition to value-based care models, they have often been forced to rely on safe harbors under the Anti-Kickback Statute, or AKS, that were never designed with value-based payment...more
The Centers for Medicare and Medicaid Services (CMS) Direct Contracting Model presents an exciting move towards value-based care with benefits for participants, providers and patients alike. However, the model raises a number...more
On March 22, 2020, the Centers for Medicare & Medicaid Services (CMS) implemented substantial administrative relief for clinicians, providers and facilities participating in Medicare quality reporting programs, including...more
On November 25, 2019, CMS released a Request for Application (RFA) describing how organizations can apply to participate in two of three Direct Contracting Model options. The Direct Contracting Model is a set of voluntary...more
The ACO Specialist Manual is a strategic guide to getting the optimum value-add contributions from each medical specialty in integrated health care. For purposes of this Manual, the teams are generally termed accountable care...more
With CMS’s continued “regulatory sprint to coordinated care,” the new Medicare Shared Savings Program regulations expand the playing field for ACOs to offer beneficiary incentive programs to encourage healthy outcomes. Termed...more
On December 31, 2018, the Centers for Medicare and Medicaid Services (CMS) published a final rule (Final Rule) establishing the “Pathways to Success” program that overhauls the Medicare Shared Savings Program (MSSP). ...more
On December 21, 2018, CMS announced a final rule, subsequently published in the December 31 issue of the federal register, significantly overhauling the Medicare Shared Savings Program (“MSSP”). Among the important changes in...more
This is the third article in our series on the new “Pathways” rules for Accountable Care Organizations. The Centers for Medicare and Medicaid Services (CMS) issued its anticipated final rule revising the Medicare Shared...more