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	<title>Comments for OMW Health Law</title>
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	<description>Health IT Blog</description>
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		<title>Comment on The Nuts and Bolts of Determining Shared Savings and Losses for ACOs. by Excelicare - Health Information Exchange</title>
		<link>http://omwhealthlaw.com/acosharedsavingsmethod/#comment-8</link>
		<dc:creator>Excelicare - Health Information Exchange</dc:creator>
		<pubDate>Wed, 21 Dec 2011 05:19:34 +0000</pubDate>
		<guid isPermaLink="false">http://omwhealthlaw.com/?p=557#comment-8</guid>
		<description>[...] The Nuts and Bolts of Determining Shared Savings and Losses for ACOs.    Posted in Collaborative Care [...]</description>
		<content:encoded><![CDATA[<p>[...] The Nuts and Bolts of Determining Shared Savings and Losses for ACOs.    Posted in Collaborative Care [...]</p>
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		<title>Comment on The Nuts and Bolts of Determining Shared Savings and Losses for ACOs. by Medicare Buz &#187; Blog Archive &#187; The Nuts and Bolts of Determining Shared Savings and Losses for ACOs.</title>
		<link>http://omwhealthlaw.com/acosharedsavingsmethod/#comment-7</link>
		<dc:creator>Medicare Buz &#187; Blog Archive &#187; The Nuts and Bolts of Determining Shared Savings and Losses for ACOs.</dc:creator>
		<pubDate>Tue, 29 Nov 2011 07:07:23 +0000</pubDate>
		<guid isPermaLink="false">http://omwhealthlaw.com/?p=557#comment-7</guid>
		<description>[...]  CMS adopted the CMS-HHC risk adjustment model that has been used under the Medicare Advantage program for adjusting the ACO&#8217;s benchmark expenditures. CMS will make additional risk adjustments for performance years to take into account changes in assigned beneficiaries.  For newly assigned beneficiaries, CMS will annually update the ACO&#8217;s CMS-HHC risk scores.  For continuously assigned beneficiaries, if there is no decline in the ACO&#8217;s CMS-HHC risk scores, CMS will use demographic factors to adjust for severity and case mix.  However, if the continuously assigned population shows a decline in its CMS-HHC risk scores, CMS will lower the risk score for that population.  An ACO&#8217;s updated benchmark will be restated in the appropriate performance year based on the health status of the ACO&#8217;s assigned beneficiaries.  In addition, CMS will make adjustments for  ESRD, disabled, aged/dual eligible Medicare and Medicaid beneficiaries and aged/non-dual eligible Medicare and Medicaid beneficiaries.Source: omwhealthlaw.com [...]</description>
		<content:encoded><![CDATA[<p>[...]  CMS adopted the CMS-HHC risk adjustment model that has been used under the Medicare Advantage program for adjusting the ACO&#8217;s benchmark expenditures. CMS will make additional risk adjustments for performance years to take into account changes in assigned beneficiaries.  For newly assigned beneficiaries, CMS will annually update the ACO&#8217;s CMS-HHC risk scores.  For continuously assigned beneficiaries, if there is no decline in the ACO&#8217;s CMS-HHC risk scores, CMS will use demographic factors to adjust for severity and case mix.  However, if the continuously assigned population shows a decline in its CMS-HHC risk scores, CMS will lower the risk score for that population.  An ACO&#8217;s updated benchmark will be restated in the appropriate performance year based on the health status of the ACO&#8217;s assigned beneficiaries.  In addition, CMS will make adjustments for  ESRD, disabled, aged/dual eligible Medicare and Medicaid beneficiaries and aged/non-dual eligible Medicare and Medicaid beneficiaries.Source: omwhealthlaw.com [...]</p>
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		<title>Comment on ACO Fraud and Abuse Law Waivers by Medicare Buz &#187; Blog Archive &#187; Ohioans take note of health law&#8217;s unaccountable Medicare board: Your Turn</title>
		<link>http://omwhealthlaw.com/acofraudwaivers/#comment-6</link>
		<dc:creator>Medicare Buz &#187; Blog Archive &#187; Ohioans take note of health law&#8217;s unaccountable Medicare board: Your Turn</dc:creator>
		<pubDate>Thu, 24 Nov 2011 03:06:54 +0000</pubDate>
		<guid isPermaLink="false">http://omwhealthlaw.com/?p=550#comment-6</guid>
		<description>[...] CMS, OIG, and HHS will closely monitor ACOs entering into the program in 2012 through June 2013, and plan to narrow the waivers if they result in the unintended effect of shielding abusive arrangements.  The waivers could be narrowed by modifying the waivers to add or substitute conditions to the waivers; limiting ACO arrangements involving referral sources to those that are fair market value or commercially reasonably or involve services performed by the referral sources; preclude waiver protections for arrangements that involve individuals or entities that are not part of the ACO; or include a requirement that ACOs submit reports regarding their arrangement.  CMS and the OIG seek comments on these approaches to narrow the waivers.Source: omwhealthlaw.com [...]</description>
		<content:encoded><![CDATA[<p>[...] CMS, OIG, and HHS will closely monitor ACOs entering into the program in 2012 through June 2013, and plan to narrow the waivers if they result in the unintended effect of shielding abusive arrangements.  The waivers could be narrowed by modifying the waivers to add or substitute conditions to the waivers; limiting ACO arrangements involving referral sources to those that are fair market value or commercially reasonably or involve services performed by the referral sources; preclude waiver protections for arrangements that involve individuals or entities that are not part of the ACO; or include a requirement that ACOs submit reports regarding their arrangement.  CMS and the OIG seek comments on these approaches to narrow the waivers.Source: omwhealthlaw.com [...]</p>
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		<title>Comment on ACO Antitrust Guidance by related sites</title>
		<link>http://omwhealthlaw.com/acoanti-trust/#comment-5</link>
		<dc:creator>related sites</dc:creator>
		<pubDate>Mon, 21 Nov 2011 20:02:35 +0000</pubDate>
		<guid isPermaLink="false">http://omwhealthlaw.com/?p=542#comment-5</guid>
		<description>Reblogged this on &lt;a href=&quot;http://ushealthreforms.net/2011/11/21/aco-antitrust-guidance/&quot; rel=&quot;nofollow&quot;&gt;ushealthreforms&lt;/a&gt; and commented: 
Interesting....!</description>
		<content:encoded><![CDATA[<p>Reblogged this on <a href="http://ushealthreforms.net/2011/11/21/aco-antitrust-guidance/" rel="nofollow">ushealthreforms</a> and commented:<br />
Interesting&#8230;.!</p>
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		<title>Comment on CMS Releases Final Rule on Accountable Care Organizations by Medicare Buz &#187; Blog Archive &#187; MHA&#8217;s Executive Briefing: The Medicare Shared Savings Program: AHA Advisory on ACO Final Rule</title>
		<link>http://omwhealthlaw.com/acofinalrule/#comment-4</link>
		<dc:creator>Medicare Buz &#187; Blog Archive &#187; MHA&#8217;s Executive Briefing: The Medicare Shared Savings Program: AHA Advisory on ACO Final Rule</dc:creator>
		<pubDate>Wed, 09 Nov 2011 17:29:59 +0000</pubDate>
		<guid isPermaLink="false">http://omwhealthlaw.com/?p=525#comment-4</guid>
		<description>[...] One-Sided Risk Model:  Under the proposed rule, all ACOs would have operated under a “two-sided” risk model where ACOs had the chance of losing money if they did not produce sufficient savings.  In the final rule, ACOs are allowed to participate in a “one-side” risk model, which will allow providers to participate in the program without risking a loss in the event that their ACO does not produce savings.  The final rule also allows ACOs to opt into a “two-sided” risk model in exchange for the opportunity to receive a greater share of savings.Source: omwhealthlaw.com [...]</description>
		<content:encoded><![CDATA[<p>[...] One-Sided Risk Model:  Under the proposed rule, all ACOs would have operated under a “two-sided” risk model where ACOs had the chance of losing money if they did not produce sufficient savings.  In the final rule, ACOs are allowed to participate in a “one-side” risk model, which will allow providers to participate in the program without risking a loss in the event that their ACO does not produce savings.  The final rule also allows ACOs to opt into a “two-sided” risk model in exchange for the opportunity to receive a greater share of savings.Source: omwhealthlaw.com [...]</p>
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