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ACO Proposed Rule: AAMC Comment Letters and Teleconference Materials

CMS released the proposed regulations for the ACO program on March 31, 2011 with a comment period through June 6, 2011. In response to provider concerns about the application of fraud and abuse, antitrust, and tax-exempt laws, three additional documents were released by the Office of the Inspector General, the IRS, the Federal Trade Commission, and the Department of Justice. Comments on the CMS/OIG notice will be accepted through June 6, and comments on the IRS and FTC/DOJ documents will be accepted through May 31.

Teleconference Materials

Webinar: ACO Benchmarking Methodology Proposed Rule, March 8, 2016 (Slides are available here )

Overview of Medicare Shared Savings Program (ACO) Proposed Rule, April 12, 2011 (Slides are available here)

Comment Letters

AAMC Comment Letter on the Medicare Shared Savings Program (ACO) Proposed Rule 

ACO Comment Letter

AAMC Letter to FTC and DOJ on ACO Proposal 


AAMC Comment Letter to IRS on ACO Proposal 


AAMC Comment Letter to CMS and OIG on Proposed Fraud and Abuse Waivers 


On Patient Care

Testimony and Correspondence