Almost exactly a year after President Obama signed health care reform legislation into law, on March 31, 2011, the Centers for Medicare and Medicaid Services (CMS) released the much-anticipated proposed rule for the Medicare Shared Savings Program.

The proposed rule was required by Section 3022 of the Patient Protection and Affordable Care Act (PPACA) and was published in the April 7 issue of the Federal Register. CMS’s proposed rule was a multi-agency effort with the following documents being issued simultaneously with CMS’s proposed rule: a joint CMS and Office of Inspector General notice and solicitation of public comments on potential waivers of certain fraud and abuse laws in connection with the Medicare Shared Savings Program; a joint Federal Trade Commission and Department of Justice proposed antitrust policy statement; and an Internal Revenue Service notice requesting comments regarding the need for additional tax guidance for tax-exempt organizations, including tax-exempt hospitals, participating in the Medicare Shared Savings Program. These encompassed hundreds of pages.

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