Gibbons Healthcare Attorneys Address Centers for Medicare & Medicaid Services on Behalf of ABA


January 12, 2012

Gibbons healthcare attorneys David N. Crapo and Barry Liss, both members of the American Bar Association Health Law Section’s Accountable Care Organization (ACO) Task Force, prepared comments that were submitted to the Centers for Medicare & Medicaid Services on behalf of the Section. The comments addressed the Interim Final Rules for final waivers in connection with the Medicare Shared Savings Program.

The comments prepared by Mr. Crapo and Mr. Liss dealt with the ACO Task Force’s concerns pertaining to waivers by CMS and the Office of Inspector General of federal anti-kickback, prohibited referrals, and civil monetary penalty laws arising in connection with ACO development under the Medicare Shared Savings Program.

The Healthcare Team at Gibbons represents physician practice groups, hospitals, federally qualified health centers, and home healthcare, visiting nurse, hospice, and other healthcare systems in various capacities as outside general counsel, and with respect to regulatory matters, reimbursement issues, network contracting, and structuring of organizations, including integrated delivery systems, accountable care organizations, and other types of joint ventures and pilot programs involving payors and providers. The Team also handles fraud and abuse counseling and defense, mergers and acquisitions, joint ventures, management agreements, and divestitures, HIPAA compliance, and broader government affairs counseling.

Mr. Crapo has represented numerous clients in connection with HIPAA and healthcare privacy issues. He is a co-editor of the Health Law Committee of the American Bankruptcy Institute and is currently pursuing an LLM degree in Health Law and Policy at Seton Hall University School of Law. Mr. Liss, former in-house counsel for Horizon Blue Cross and Blue Shield of New Jersey, Inc., was recently confirmed by the New Jersey Senate to the state’s Catastrophic Illness in Children Relief Fund Commission.