ACO COMPLIANCE PLANS

Under the CMS proposed rule, an ACO (Accountable Care Organization) must have a compliance plan.  At minimum, an ACO compliance plan must have the following five elements:

1. A designated compliance official or individual who is not legal counsel to the ACO and who reports directly to the ACO’s governing body

2. Mechanisms for identifying and addressing compliance problems related to the ACO’s operations and performance

3. A method for employees or contractors of the ACO or ACO providers/suppliers to report suspected problems related to the ACO

4. Compliance training of the ACO’s employees and contractors

5. A requirement to report suspected violations of law to an appropriate law enforcement agency.

To read the proposed rule in full, go here.

(Disclaimer: This blog is not intended as legal advice nor does it create an attorney-client relationship.  If you have questions relating to ACO compliance plans, please contact Matthews Law Firm, P.A.)

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