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CMS-1403-FC
date. We seek comments regarding [49] necessary safeguards
to ensure that a final exception for shared savings
programs, when considered in its totality, would not
present a risk of program or patient abuse if we permitted
the sharing of departmental or service line global cost
savings. In addition, we are interested in [50] the impact
that sharing such savings with physicians would have on
other potential requirements of a final exception, such as
the requirement that the calculation of cost savings and
physician payments be audited.
(3) Miscellaneous
We request comments on [51] whether the exception
should protect contracts/arrangements between hospitals and
physician groups or only contracts/arrangements between
hospitals and individual referring physicians (and, if the
exception should allow contracts/arrangements between
hospitals and physician groups, how we could protect
against payments to physicians who do not actively
participate in the program and who might be rewarded merely
for making referrals). Also, we seek comments on [52]
whether, if a physician group participates, the physician
group may be paid if some of its physicians fail to make
quality improvements; and [53] whether all physicians in
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