This advanced course provides a comprehensive examination of the legal architecture, governance structure, reimbursement mechanics, and enforcement risks associated with Accountable Care Organizations (ACOs) in the United States. ACOs represent a foundational component of healthcare payment reform, shifting from fee-for-service reimbursement to coordinated, value-based care models that reward cost control and quality performance.
The course analyzes statutory authority under the Affordable Care Act, regulatory implementation by the Centers for Medicare & Medicaid Services (CMS) within the Department of Health and Human Services, and enforcement considerations involving the U.S. Department of Justice and the HHS Office of Inspector General.
Participants will explore:
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Medicare Shared Savings Program (MSSP) structure
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Governance and legal entity formation
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Risk-sharing arrangements
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Fraud and abuse waivers
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Antitrust considerations
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Data-sharing and privacy issues
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Contracting with participants and providers
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Downside risk and financial exposure
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Compliance and enforcement trends
This course is designed for advanced law students, healthcare attorneys, compliance professionals, hospital executives, and policy advisors engaged in value-based care models.
COURSE OBJECTIVES
By the end of this course, participants will be able to:
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Analyze the statutory and regulatory foundation of ACOs.
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Structure ACO legal entities and governance models.
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Evaluate shared savings and downside risk frameworks.
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Apply fraud and abuse waivers in ACO arrangements.
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Identify antitrust risks in collaborative healthcare models.
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Draft and analyze ACO participation agreements.
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Assess data governance and HIPAA compliance.
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Model financial risk exposure under value-based contracts.
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Navigate enforcement investigations involving ACOs.
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Advise boards and executives on ACO governance and compliance.

