Clinical Integration and ACO Alert 

News and Information from Broad and Cassel's Health Law Practice Group

January 2014
Volume 4, Issue 1
Practice Group Update
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 Upcoming Speaking Engagements

Gabriel Imperato:

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Mike Segal


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 Vanessa Reynolds 

 Vanessa Reynolds


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 Stephen Siegel  

 Stephen Siegel

Of Counsel

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Christine Burke Worthen

Of Counsel

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Heather Miller (New)  

Heather S. Miller

Senior Counsel

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Ramona Thomas  

To our clients and friends:


The last quarter of the year traditionally is reserved for reflection and making resolutions to implement improvements/changes in the new year. The truth of the matter is most of us are too busy to engage in reflection and planning activities. In today's healthcare business environment that can be a serious mistake.


One of the growing trends over the past 18 months has been the emergence of accountable care organizations ("ACO"), patient center medical homes ("PCMH") and other affiliations of healthcare providers to address the needs of individual patients and patient populations. In large part, the affiliation drive is based upon changes in the manner in which healthcare is going to be reimbursed in the near future. The focus today is on establishing metrics that reward healthcare providers who provide cost effective services to populations of patients, rather than those who are able to inflate the cost of care.


We already have seen efforts to squeeze payments to healthcare providers. ACOs, bundled payments and other mechanisms that are being developed will reduce the availability of fee-for-service reimbursement. For many healthcare providers the question today is whether they believe that their future is likely to be better alone, or as a part of one of these affiliated delivery systems. The start of the year provides a point in time to put this question into focus.


Stephen Siegel
Of Counsel

Broad and Cassel

Medicare ACO's: Compliance Checkup

By: Christine Burke Worthen


With the prospect of an audit a reality for those participating in the Medicare Shared Savings Program or the Pioneer ACO Program, ACO's should periodically review their compliance with the obligations set forth in the Final Rule and their agreements with CMS. This article will offer a selection of "hot topics" that ACO's may want to consider in reviewing their compliance with the ACO program rules.


Organizational Matters


The ACO should take care to ensure that any changes to its original structure are appropriately documented and continue to support the ACO in accomplishing its goals and objectives.


Please click here to continue reading.


By: Vanessa Reynolds


One of the underlying principles of Accountable Care Organizations (ACO) is shared health spending savings and risks, which requires the sharing of protected health information (PHI).   All parties to an ACO or other Organized Health Care Arrangement (OHCA) must therefore be mindful and observant of HIPAA's requirements, including the requirement for business associate agreements.


As the relationships between the parties to OHCAs become more complex, so, too, are the relationships between covered entities, business associates and their downstream business associates. Depending on the arrangement or transaction, ACOs and providers may be covered entities, business associates, or both.


Click here for the full article.

First Coast Health Alliance and Florida Blue Form Accountable Care Program

By: Ramona Thomas


In yet another new accountable care shared savings project, this time in North Florida, First Coast Health Alliance has announced that it has teamed up with Florida Blue. The announcement came out on January 14, 2014, confirming that the Jacksonville-based physician-hospital organization will work together with Florida's Blue Cross Blue Shield company to establish an accountable care program.


This program, which started on January 1st, is "focused on improving the health of patients and populations served in St. John's county and surrounding areas." The program will strive to enhance the quality and efficiency of patient care provided in the region.


Please click here to read further.

 About Us
With more than 20 attorneys and a full complement of support staff, Broad and Cassel's Health Law Practice Group is intimately aware of the complex issues faced by health care providers, suppliers and consumers. 

Fundamental changes to the nation's health care delivery system are occurring at an accelerated rate, requiring those in the industry to establish and refine their practices and policies to comply with new regulations. The attorneys of our Health Law Practice Group are prepared to discuss these changes and the potential impact they will have on health care providers of all types.