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Posts Tagged ‘Accountable Care Organizations’

CMS Releases Final Rules Under Medicare Shared Savings Program

Tuesday, June 21st, 2016
  • final aco rule revision 2016 msspMSSP Final Rules Revision ACO Requirements Under Shared Savings Program – 2016 Revised MSSP Regulations Issues

On June 10, just in time for my birthday (thanks CMS), the Centers for Medicare & Medicaid Services (CMS) released final rules amending the regulatory requirement applicable to the Medicare Shared Savings Program (MSSP). The Final Rules that were published on June 10, 2016 state the intent to encourage additional participation in the program and to ease financial burdens on participating Accountable Care Organizations (ACOs). The regulations attempt to provide incentives for existing ACOS to renew their participation and elect to pursue higher levels of risk. The revised rules reflect an element of additional flexibility that ACOs may be able to take advantage of when transitioning between participation tracks.

There are a variety of changes in the new regulations. A few of these changes include:

  • Clarifications regarding times that shared savings and shared loss claims may be re-opened by CMS.
  • Changes in how benchmarks will be calculated beginning in 2017. (Increasing consideration of regional Medicare expenditures total population health of the population that is assigned to the ACO).
  • Adoption of adjustments based on average fee-for-service Medicare expenditures applicable to the relevant regional service area for purposes of calculating benchmark adjustments. County-by-county averages will be utilized for expenditures attributable to the total cost of services to beneficiaries within the applicable county.
  • Adoption of risk-adjustment factors when revising an ACO’s benchmarks. Risk adjustment is to be based on the relative health status of the ACO’s assigned population.
  • Revision of the manner in which CMS performs truncating and trending calculations.

The new rules clarify that CMS has the authority to reopen and make revisions to MSSP payments in cases of fraud and for other similar reasons. Even when fraud does not exist, CMS will have four years after providing notice of initial determination of shared savings or loss to reopen and revise for any good cause. Unfortunately, there is not definition of what constitutes “good cause” in the new rules. In comments, CMS indicates that it will excercise this authority where there evidence that was previously unavailable evidence that indicates error in the original determination or where previously available evidence is clearly determined to have been relied on erroneously. This rather broad “reopening” authority presents significant financial uncertainty for ACOs.

Under the new rules, ACOs will now be able to remain in Track 1 for a fourth year before transitioning into Tracks 2 and 3 which involve higher degrees of risk. Additionally, ACOs that choose to progress to higher risk tracks will be able to have their benchmark recalculation deferred for an additional year. These changes are being made to make it easier for ACOs to transition to higher risk tracks.


CMS Comments On ACO Participation Agreement Requirements

Friday, August 7th, 2015

MSSP ACO Agreement Requirements

CMS Comment Describing Provider Agreement Requirements for Participation In the Medicare Shared Savings Program

ACO Participation Agreement MSSP Participation Section 1899(b)(2)(B) of the Act requires participating ACOs to “enter into an agreement with the Secretary to participate in the program for not less than a 3-year period.” If the ACO is approved for participation in the Shared Savings Program, an executive who has the ability to legally bind the ACO must sign and submit a participation agreement to CMS (Sec.  425.208(a)(1)). Under the participation agreement with CMS, the ACO agrees to comply with the regulations governing the Shared Savings Program (Sec.  425.208(a)(2)).

In addition, the ACO must require its ACO participants, ACO providers/suppliers, and other individuals or entities performing functions or services related to the ACO’s activities to agree to comply with the Shared Savings Program regulations and all other applicable laws and regulations (Sec.  425.208(b) and Sec.  425.210(b)). The ACO must provide a copy of its participation agreement with CMS to all ACO participants, ACO providers/suppliers, and other individuals and entities involved in ACO governance (Sec.  425.210(a)). As part of its application, we currently require each ACO to submit a sample of the agreement it executes with each of its ACO participants (the “ACO participant agreement”). Also, as part of its application and when requesting the addition of new ACO participants, we require an ACO to submit evidence that it has a signed written agreement with each of its ACO participants. (See guidance on our Web site at

ACO Participation In MSSP Will Not Be Approved Unless The ACO Has An Agreement In Place With Participating Providers.

An ACO’s application to participate in the Shared Savings Program and any subsequent request to add new ACO participants will not be approved if the ACO does not have an agreement in place with each of its ACO participants in which each ACO participant agrees to participate in the Shared Savings Program and to comply with the requirements of the Shared Savings Program.

CMS Describes inadequate Provider Agreements From Previous Application Periods

In our review of applications to participate in the Shared Savings Program, we received many ACO participant agreements that were not properly executed, were not between the correct parties, lacked the required provisions, contained incorrect information, or failed to comply with Sec.  425.304(c) relating to the prohibition on certain required referrals and cost shifting. When we identified such agreements, ACOs experienced processing delays, and in some cases, we were unable to approve the ACO applicant and/or its ACO participant to participate in the Shared Savings Program. Consequently, we issued guidance for ACO applicants in which we reiterated the required elements for ACO participant agreements and strongly recommended that ACOs employ good contracting practices to ensure that each of their ACO participant agreements met our requirements (see

The ACO participant agreements are necessary for purposes of program transparency and to ensure an ACO’s compliance with program requirements. Moreover, many important program operations (including calculation of shared savings, assignment of beneficiaries, and financial benchmarking), use claims and other information that are submitted to CMS by the ACO participant. Our guidance clarified that ACO participant agreements and any agreements with ACO providers/suppliers must contain the following:

  • An explicit requirement that the ACO participant or the ACO provider/supplier will comply with the requirements and conditions of the Shared Savings Program (part 425), including, but not limited to, those specified in the participation agreement with CMS.
  • A description of the ACO participants’ and ACO providers’/suppliers’ rights and obligations in and representation by the ACO.
  • A description of how the opportunity to get shared savings or other financial arrangements will encourage ACO participants and ACO providers/suppliers to follow the quality assurance  and improvement program and evidence-based clinical guidelines.
  • Remedial measures that will apply to ACO participants and ACO providers/suppliers who do not comply with the requirements of their agreements with the ACO.

Agreement Must Be Direct With the Provider and Not Through an IPA

Our guidance also requires that the ACO participant agreements be made directly between the ACO and the ACO participant. We believe it is important that the parties entering into the agreement have a direct legal relationship to ensure that the requirements of the agreement are fully and directly enforceable by the ACO, including the ability of the ACO to terminate an agreement with an ACO participant that is not complying with the requirements of the Shared Savings Program.

Additionally, a direct legal relationship ensures that the ACO participant may, if necessary, terminate the agreement with the ACO according to the terms of the agreement without interrupting other contracts or agreements with third parties. Therefore, the ACO and the ACO participant must be the only parties to an ACO participant agreement; the agreements may not include a third party to the agreement. For example, the agreement may not be between the ACO and another entity, such as an independent practice association (IPA) or management company that in turn has an agreement with one or more ACO participants. Similarly, existing contracts between ACOs and ACO participants that include third parties should not be used.

We recognize that there are existing contractual agreements between entities (for example, contracts that permit organizations like IPAs to negotiate contracts with health care payers on behalf of individual practitioners). However, because it is important to ensure that there is a direct legal relationship between the ACO and the ACO participant evidenced by a written agreement, and because ACO participants continue to bill and receive payments as usual under the Medicare FFS rules (that is, there is no negotiation for payment under the program) we believe that typical IPA contracts are generally inappropriate and unnecessary for purposes of participation in the Shared Savings Program. An ACO and ACO participant may use a contract unrelated to the Shared Savings Program as an ACO participant agreement only when it is between the two parties and is amended to satisfy the requirements for ACO participant agreements under the Shared Savings Program.

Assure That Agreements Are In Correct Legal Names and Are Consistent With PECOS Information

It is the ACO’s responsibility to make sure that each ACO participant agreement identifies the parties entering into the agreement using their correct legal names, specifies the term of the agreement, and is signed by both parties to the agreement. We validate the legal names of the parties based on information the ACO submitted in its application and the legal name of the entity associated with the ACO participant’s TIN in the Provider Enrollment Chain & Ownership System (PECOS). We reject an ACO participant agreement if the party names do not match our records. It may be necessary for the ACO to execute a new or amended ACO participant agreement.

Although the ACO participant must ensure that each of its ACO providers/suppliers (as identified by a National Provider Identifier (NPI)) has agreed to participate in the ACO and will comply with program rules, the ACO has the ultimate responsibility for ensuring that all the ACO providers/suppliers that bill through the TIN of the ACO participant (that is, reassign their right to receive Medicare payment to the ACO participant) have also agreed to participate in the Shared Savings Program and comply with our program regulations. The ACO may ensure this by directly contracting with each ACO provider/supplier (NPI) or by contractually requiring the ACO participant to ensure that all ACO providers/suppliers that bill through its TIN have agreed to participate in, and comply with the requirements of, the Shared Saving Program. If the ACO chooses to contract directly with the ACO providers/suppliers, the agreements must meet the same requirements as the agreements with ACO participants. We emphasize that even if an ACO chooses to contract directly with the ACO providers/suppliers (NPIs), it must still have the required ACO participant agreement. In other words, the ACO must be able to produce valid written agreements for each ACO participant and each ACO provider/supplier. Furthermore, since we use TINs (and not merely some of the NPIs that make up the entity identified by a TIN) as the basis for identifying ACO participants, and we use all claims submitted under an ACO participant’s TIN for financial calculations and beneficiary assignment, an ACO may not include an entity as an ACO participant unless all Medicare enrolled providers and suppliers billing under that entity’s TIN have agreed to participate in the ACO as ACO providers/suppliers.

CMS Illustrations of Contracting Requirements for ACO Participation Agreements

To illustrate the requirement that all ACO providers/suppliers must agree to participate in and comply with the terms of the Shared Savings Program before the ACO can include the ACO participant’s TIN on its list of ACO participants, we offer the following scenarios that describe when an ACO participant’s TIN may and may not be included on the applicant’s ACO participant list:

Correct: A large group practice (Medicare-enrolled TIN) decides to participate in an ACO as an ACO participant. Its owner signs an agreement with the ACO on behalf of the practice to participate in the program and follow program regulations. Also, all practitioners that have reassigned their right to receive Medicare payments to the TIN of the large group practice have also agreed to participate and follow program regulations. Therefore, the ACO may include this group practice TIN on its list of ACO participants.

Incorrect: A large group practice (Medicare-enrolled TIN) decides to participate in an ACO as an ACO participant. Its owner signs an agreement to participate in the program and follow program regulations. However, not all practitioners that have reassigned their right to receive Medicare payment to the group practice TIN have agreed to participate in the ACO and follow Shared Savings Program regulations. Therefore, the ACO may not include this group practice TIN on its list of ACO participants.

Incorrect: Several practitioners in a large group practice (Medicare-enrolled TIN) decide to participate in an ACO. However, the group practice as a whole has not agreed to participate in the program. Therefore, the ACO may not include this group practice TIN on its list of ACO participants.

We propose to codify much of our guidance regarding the content of the ACO participant and ACO provider/supplier agreements.

b. Proposed Revisions

First, we propose to add new Sec.  425.116 to set forth the requirements for agreements between an ACO and an ACO participant or ACO provider/supplier. We believe the new provision would promote a better general understanding of the Shared Savings Program and transparency for ACO participants and ACO providers/suppliers. It is our intent to provide requirements that would facilitate and enhance the relationships between ACOs and ACO participants, and reduce uncertainties and misunderstandings leading to rejection of ACO participant agreements during application review. Specifically, we propose to require that ACO participant agreements satisfy the following criteria:

  • The ACO and the ACO participant are the only parties to the agreement.
  • The agreement must be signed on behalf of the ACO and the ACO participant by individuals who are authorized to bind the ACO and the ACO participant, respectively.
  • The agreement must expressly require the ACO participant to agree, and to ensure that each ACO provider/supplier billing through the TIN of the ACO participant agrees, to participate in the Shared Savings Program and to comply with the requirements of the Shared Savings Program and all other applicable laws and regulations (including, but not limited to, those specified at Sec.  425.208(b)).
  • The agreement must set forth the ACO participant’s rights and obligations in, and representation by, the ACO, including without limitation, the quality reporting requirements set forth in Subpart F, the beneficiary notification requirements set forth at Sec.  425.312, and how participation in the Shared Savings Program affects the ability of the ACO participant and its ACO providers/suppliers to participate in other Medicare demonstration projects or programs that involve shared savings.
  • The agreement must describe how the opportunity to receive shared savings or other financial arrangements will encourage the ACO participant to adhere to the quality assurance and improvement program and evidence-based medicine guidelines established by the ACO.
  • The agreement must require the ACO participant to update enrollment information with its Medicare contractor using the PECOS, including the addition and deletion of ACO professionals billing through the TIN of the ACO participant, on a timely basis in accordance with Medicare program requirements. The Agreement must also require ACO participants to notify the ACO within 30 days after any addition or deletion of an ACO provider/supplier.
  • The agreement must permit the ACO to take remedial action against the ACO participant, and must require the ACO participant to take remedial action against its ACO providers/suppliers, including imposition of a corrective action plan, denial of shared savings payments (that is, the ability of the ACO participant or ACO provider/supplier to receive a distribution of the ACO’s shared savings) and termination of the ACO participant agreement, to address noncompliance with the requirements of the Shared Savings Program and other program integrity issues, including those identified by CMS.
  • The term of the agreement must be for at least 1 performance year and must articulate potential consequences for early termination from the ACO.
  • The agreement must require completion of a close-out process upon the termination or expiration of the ACO’s participation agreement that requires the ACO participant to furnish data necessary to complete the annual assessment of the ACO’s quality of care and addresses other relevant matters.

Although we propose that the term of an ACO participant agreement be for at least 1 performance year, we do not intend to prohibit early termination of the agreement. We recognize that there may be legitimate reasons to terminate an ACO participant agreement. However, because care coordination and quality improvement requires commitment from ACO participants, we believe this requirement would improve the likelihood of success in the Shared Savings Program. We are also considering whether and how ACO participant agreements should encourage participation to continue for subsequent performance years. We seek comment on this issue.

ACOs That Choose To Contract Directly With ACO Providers/Supplier 

In the case of an ACO that chooses to contract directly with its ACO providers/suppliers, we propose virtually identical requirements for its agreements with ACO providers/suppliers. We note that agreements with ACO providers/suppliers would not be required to be for a term of 1 year, because we do not want to impede individual practitioners from activities such as retirement, reassignment of billing rights, or changing employers. In the case of ACO providers/suppliers that do not have a contract directly with the ACO, we are considering requiring each ACO to ensure that its ACO participants contract with or otherwise arrange for the services of its ACO providers/suppliers on the same or similar terms as those required for contracts made directly between the ACO and ACO providers/suppliers.

In addition, we propose to add at Sec.  425.204(c)(6) a requirement that, as part of the application process and upon request thereafter, the ACO must submit documents demonstrating that its ACO participants, ACO providers/suppliers, and other individuals or entities performing functions or services related to ACO activities are required to comply with the requirements of the Shared Savings Program. In the case of ACO participants, the evidence to be submitted must, consistent with our past guidance, include executed agreements or sample form agreements together with the first and last (signature) page of each form agreement that has been fully executed by the parties to the agreement.

However, we reserve the right, to request all pages of an executed ACO participant agreement to confirm that it conforms to the sample form agreement submitted by the ACO. We further propose at Sec.  425.116(c) that executed ACO participant agreements must also be submitted when an ACO seeks approval to add new ACO participants. The agreements may be submitted in the same form and manner as set forth in Sec.  425.204(c)(6). Finally, although we would not routinely request an ACO to submit copies of executed agreements with its ACO providers/suppliers or other individuals or entities performing functions or services related to ACO activities as part of the ACO’s application or continued participation in each performance year, we reserve our right to request this information during the application or renewal process and at any other time for audit or monitoring purposes in accordance with Sec.  425.314 and Sec.  425.316.

We believe that the proposed requirements regarding agreements between ACOs and ACO participants, together with our earlier guidance regarding good contracting practices, would enhance transparency between the ACO, ACO participants, and ACO professionals, reduce turnover among ACO participants, prevent misunderstandings related to participation in the Shared Savings Program, and assist prospective ACOs in submitting complete applications and requests for adding ACO participants. We believe that codifying these requirements would assist the ACO, ACO participants, and ACO providers/suppliers in better understanding the program and their rights and responsibilities while participating in the program. We solicit comment on the proposed new requirements and on whether there are additional elements that should be considered for inclusion in the agreements the ACO has with its ACO participants and ACO providers/suppliers.

Physician Specialty Group Affiliations and ACO Involvement

Wednesday, July 18th, 2012

Specialty Affiliations and Mergers – Consider How You Fit Into An Accountable Care Organization

Merging Physician Specialty PracticesOne result of health care reform is a resurgence in affiliations and mergers of specialty practices throughout the country.  The structures of various physician specialty consolidations take a variety of forms, from IPAs, to divisional model groups, through completely integrated group practices.  Each structure raises its own legal considerations and challenges.  Regardless of what structure is used to consolidate specialty practices, the end result must be to create a facility to assure optimal participation under a reformed health care system.  This necessarily will include assuring participation in an Accountable Care Organization.

Specialty groups need to create a structure that does not exclude them from participation in an ACO.  One thing to consider when structuring a specialty group affiliation is the size and market share of the group in relation to the ACO antitrust safety zone that was issued by the Federal Trade Commission and the Department of Justice.  The ACO safety zone provides that an organization that meets the requirements to be an Accountable Care Organization will be considered to be “clinically integrated” under the antitrust laws. The DOJ and FTC state that they will not challenge ACOs that fall within the safety zone, absent extraordinary circumstances.

Normally, an organization that consists of independent competing physicians and other providers cannot jointly contract because an agreement on pricing issues amounts to a per se violation of the antitrust laws.  The goal in structuring such an organization is to provide for clinical and/or financial integration that is sufficient to take the organization out of the per se analysis into what is called the “rule of reason” analysis.  The per se rule means that the organization is automatically deemed to violate the antitrust laws.  On the other hand, the rule of reason involves a weighing of the pro-competitive affects of the organization against the anti-competitive affects.  The ACO Safety Zone amounts to a proclamation by the agencies that groups that meet the requirements to be an ACO will be judged under the more lenient “rule of reason.”

The ACO Safety Zone does not stop there.  It goes on to define when an organization will receive favorable analysis under the rule of reason.  For an ACO to fall within the safety zone, independent ACO participants that provide the same service (a “common service”) must have a combined share of 30 percent or less of each common service in each participant’s service area (“PSA”) wherever two or more ACO participants provide that service to patients from that PSA. The PSA for each participant is defined as the lowest number of postal zip codes from which the participant draws at least 75 percent of its patients, separately for all physician, inpatient, or outpatient services. Thus, for purposes of determining whether the ACO is eligible for the safety zone, each independent physician solo practice, each fully integrated physician group practice, each inpatient facility, and each outpatient facility will have its own PSA.

The Safety Zone adds some elements of certainty that did not exist under the usual “rule of reason” analysis.  For example, the Safety Zone contains a definition of the “market” to be used for purposes of safety zone analysis.  Normally the definition of “market” is a factual issue which makes an antitrust analysis difficult.  For ACO Safety Zone purposes we know that the market is considered to be the lowest number of postal zip codes from which the participant draws at least 75 percent of its patients.

Specialty organizations should keep these numbers in mind when determining the breadth of participation in their organizations.  Less integrated groups such as IPA and divisional model groups should perform this analysis and structure their groups to fall within the ACO Safety Zone.  Larger groups will have troubles plugging into an ACO that wishes to take advantage of the ACO Safety Zone.

These requirements only apply to independent groups.  A fully integrated physician group is considered to be a “single actor” for purposes of the antitrust and is therefore unable to conspire with itself on pricing issues.  This begs the question of what constitutes a “fully integrated” group for purposes of the antitrust laws.  Certainly a group that results from the merger of various practices, all who become employees of the new organization, without the creation of a divisional structure, would be considered to be a “fully integrated group.”  On the other hand, an IPA of individual practices or smaller groups would not be considered to be a “fully integrated” group.  Structures that fall between these two extremes constitute a “gray area.”  A Divisional Model Group or a Group Practice Without Walls, that has very little centralization of governance or activities and maintains most of its structure at the division or practice site level, could potentially raise questions as to whether sufficient levels of integration have been achieved to create a “fully integrated” group.

Because of the sensitivity of IPAs and divisional model structures, it is important that groups consult with competent health care or antitrust counsel who has sufficient sensitivity to these issues.  Failure to properly design a group can lead to future questions about the group’s ACO participation.  For example, if a divisional model contains more than 30% of the providers in the relevant PSA and is “collapsed” for antitrust purposes, the group’s participation in the ACO may be questioned by the ACO organizers.  Divisional models are being used frequently as a method to consolidate physicians because of the relative ease of implementing the structure.  Recently, there have been rumors that the FTC may be examining divisional groups to determine whether they are integrated enough to support them being considered a “fully integrated” group.

The same analysis applies to an IPA which is not financially integrated and includes over 30% of the providers in the local market.  In the end, you do not want to have your purposes of forming the group frustrated because these issues were not properly considered when structuring the organization.

89 New Accountable Care Organizations Announced By CMS

Tuesday, July 17th, 2012

CMS Announces 89 New Accountable Care Organizations

The Centers for Medicare & Medicaid Services (CMS) has announced 89 new organizations that qualify to participate as Accountable Care Organizations (ACOs) under the Medicare Shared Saving Program.  The organizations were announced on July 9, 2012 and include the following organizations:

  • Arizona Health Advantage, Inc, Chandler, Arizona
  • John C. Lincoln Accountable Care Organization, LLC, Phoenix, Arizona
  • Fort Smith Physicians Alliance ACO, LLC, Smith, Arkansas
  • ApolloMed Accountable Care Organization Inc., Glendale, California
  • Golden Life Healthcare LLC, Sacramento, California
  • John Muir Physician Network, Walnut Creek, California
  • Meridian Holdings, Inc., Hawthorne, California
  • North Coast Medical ACO, Inc., Oceanside, California
  • Torrance Memorial Integrated Physicians, LLC, Torrance, California
  • MPS ACO Physicians, LLC, Middletown, Connecticut
  • PriMed, LLC, Shelton, Connecticut
  • Accountable Care Coalition of Northwest Florida, LLC, Pensacola, Florida
  • Accountable Care Partners, LLC,  Jacksonville, FloridaAllcare Options, LLC, located in Parrish, Florida
  • Florida Medical Clinic ACO, LLC,  Zephyrhills, Florida
  • FPG Healthcare, LLC, Orlando, Florida
  • HealthNet LLC, Boynton Beach, Florida
  • Integrated Care Alliance, LLC, Gainesville, Florida
  • Medical Practitioners for Affordable Care, LLC, Melbourne, Florida
  • Palm Beach Accountable Care Organization, LLC, West Palm Beach, Florida
  • Reliance Healthcare Management Solutions, LLC, Tampa, Florida
  • WellStar Health Network, LLC, Marietta, Georgia
  • Advocate Health Partners, Rolling Meadows, Illinois
  • Chicago Health System ACO, LLC, Westmont, Illinois
  • Deaconess Care Integration, LLC, Evansville, Indiana
  • Franciscan AHN ACO, LLC, Mishawaka, Indiana
  • Indiana University Health ACO, Inc., Indianapolis, Indiana
  • Genesis Accountable Care Organization, LLC, Davenport, Iowa
  • Iowa Health Accountable Care, L.C., Des Moines, Iowa
  • One Care LLC, Des Moines, Iowa
  • University of Iowa Affiliated Health Providers, LC, Iowa City, Iowa
  • Owensboro ACO, Owensboro, Kentucky
  • Quality Independent Physicians, Louisville, Kentucky
  • Southern Kentucky Health Care Alliance
  • TP-ACO LLC, Baton Rouge, Louisiana
  • Central Maine ACO, Lewiston, Maine
  • Maine Community Accountable Care Organization, LLC
  • MaineHealth Accountable Care Organization, Portland, Maine
  • Accountable Care Coalition of Maryland, LLC, Hollywood, Maryland
  • Greater Baltimore Health Alliance Physicians, LLC, Baltimore, Maryland
  • Maryland Accountable Care Organization of Eastern Shore LLC, National Harbor, Maryland
  • Circle Health Alliance, LLC, Lowell, Massachusetts
  • Harbor Medical Associates, PC, South Weymouth, Massachusetts
  • Accountable Healthcare Alliance, PC, East Lansing, Michigan
  • Oakwood Accountable Care Organization, LLC, Dearborn, Michigan
  • Southeast Michigan Accountable Care, Inc., Dearborn, Michigan,
  • Essential Health, Duluth, Minnesota
  • Medical Mall Services of Mississippi, Jackson, Mississippi,
  • BJC HealthCare ACO, LLC, St. Louis, Missouri
  • Heartland Regional Medical Center, St. Joseph, Missouri
  • Nevada Primary Care Network ACO, LLC, Las Vegas, Nevada
  • Concord Elliot ACO LLC, Manchester, New Hampshire
  • Barnabas Health ACO-North, LLC, West Orange, New Jersey
  • Accountable Care Coalition of Syracuse, LLC, Syracuse, New York
  • Asian American Accountable Care Organization, New York City
  • Balance Accountable Care Network, New York City
  • Beacon Health Partners, LLP, Manhasset, New York
  • Chautauqua Region Associated Medical Partners, LLC, Jamestown, New York
  • Healthcare Provider ACO, Inc., Garden City, New York
  • Mount Sinai Care, LLC, New York City
  • ProHEALTH Accountable Care Medical Group, PLLC, Lake Success, New York
  • WESTMED Medical Group, PC, Purchase, New York
  • Cornerstone Health Care, PA, High Point, North Carolina
  • Triad Healthcare Network, LLC, Greensboro, North Carolina
  • Mercy Health Select, LLC, Cincinnati, Ohio
  • ProMedica Physician Group, Inc., Toledo, Ohio
  • Summa Accountable Care Organization, Akron, Ohio
  • University Hospitals Coordinated Care, Shaker Heights, Ohio
  • North Bend Medical Center, Inc., Coos Bay, Oregon
  • Coastal Medical, Inc., Providence, Rhode Island
  • Accountable Care Coalition of The Tri-Counties, LLC, Charleston, South Carolina
  • AnewCare LLC, Johnson City, Tennessee
  • Cumberland Center for Healthcare Innovation, LLC, Nashville, Tennessee
  • MissionPoint Health Partners,  Nashville, Tennessee
  • St. Thomas Medical Group PLLC, Nashville, Tennessee
  • Summit Health Solutions, Knoxville, Tennessee
  • BHS Accountable Care, LLC, San Antonio, Texas
  • Memorial Hermann Accountable Care Organization, Houston, Texas
  • Methodist Patient Centered ACO, Dallas, Texas
  • Essential Care Partners, LLC, Austin, Texas,
  • Physicians ACO, LLC, Houston, Texas
  • Texoma ACO, LLC, Wichita Falls, Texas
  • Central Utah Clinic, P.C., Provo, Utah
  • Accountable Care Coalition of Green Mountains, LLC, South Burlington, Vermont
  • Polyclinic Management Services Company, Seattle, Washington,
  • Aurora Accountable Care Organization LLC, Milwaukee, Wisconsin
  • Dean Clinic and St. Mary’s Hospital Accountable Care Organization, LLC,  Madison, Wisconsin
  • ProHealth Solutions, LLC, Waukesha, Wisconsin

John H. Fisher

Health Care Counsel
Ruder Ware, L.L.S.C.
500 First Street, Suite 8000
P.O. Box 8050
Wausau, WI 54402-8050

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Fax 715.845.2718

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