The accountable care organization proposed rule shows the Centers for Medicare and Medicaid Services really listened to industry concerns as it wrote the provisions, contends Paul Keckley, executive director at Deloitte Center for Health Solutions, a research arm of consultancy Deloitte LLP.

"They heard that not everyone was ready to be in an integrated group," Keckley says.  For instance, the rule addresses concerns with ACOs running afoul of federal fraud, abuse and referral laws. The rule also recognizes the varying level of readiness of organizations to participate in the Shared Savings Program by setting up two ways to participate.

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