More ACO Details Emerge

Any ACO qualified by CMS for participation in the Medicare Shared Savings Program will be judged under the “rule of reason,” which is a higher threshold for a finding of illegal restraints on trade and should provide more flexibility in devising ACO structures. For...

Big Brother is Watching…Even More Closely

As noted in the last issue of STAT Health Care News, the federal government will be stepping up its enforcement of the health care laws. In addition to increasing funding for such enforcement, the new health care reform law, the Patient Protection and Affordable Care...

The Importance of “Internal” Corporate Documents

In my practice, which covers both transactional and litigation matters, I frequently talk to clients who have started a new business entity, but neglected to create what I will call “internal” corporate documents (as opposed to the “external” documents filed with the...