Expanding Health Care Coverage

Project Title

The Development of Accountable Care Organizations: Implications for New York State

Grant Amount


Priority Area

Expanding Health Care Coverage

Date Awarded

April 4, 2011








The Accountable Care Organization (ACO) is a promising new model to slow rising health care costs and improve quality of care.

An ACO formally brings together a set of non-affiliated providers, ideally including primary care physicians, specialists, community health centers, hospitals, and post-acute care providers, and holds them accountable for the cost and quality of care delivered to a defined population of patients. With support from NYHealth, Manatt Health Solutions analyzed Federal regulations released in April 2011 that addressed legal issues facing ACOs. Manatt also produced a report.

Grant Goals:

Manatt hoped to achieve the following goals:

  • Analyze legal issues related to the ACO regulations within the Medicare Shared Savings program.
  • Examine policy issues as policymakers, providers, and other organizations consider developing and implementing ACOs in the State.
  • Produce a public report to advance understanding of the regulations and considerations to operationalize ACOs in New York.

Grant Outcomes:

  • Manatt accomplished the following:
  • Analyzed the proposed ACO regulations (released by CMS in April 2011), as well as the proposed “Pioneer Model” regulations (released in May 2011) for organizations with experience in coordinating care and accepting risk-sharing arrangements.
  • Examined the implications of these regulations, with a lens to the current New York health care and regulatory landscape.
  • Produced a June 2011 report titled, “Considerations for the Development of Accountable Care Organizations in New York State.”
  • Featured highlights of the report’s analysis in an electronic newsletter sent to 3,800 national and State legal experts, researchers, and policymakers.
  • Found that fragmentation in New York’s health care market may present a barrier to the implementation of ACOs.
  • Determined that the proposed ACO rules do not preempt State laws and regulations; thus, the development of ACOs must comply with New York’s existing statutes and regulations.

Grantee Information:

  • Grantee Website: http://www.manatt.com/
  • Grantee Amount: $40,000

Read the report associated with this grant, “Considerations in the Developement of Accountable CAre Organizations in New York State.”