National Assn. of Children's Hospitals
Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017
On behalf of children’s hospitals across the country, the National Association of Children’s Hospitals (N.A.C.H.) appreciates the opportunity to provide comments on the “Proposed Statement of Antitrust Enforcement Policy Regarding ACOs Participating in the Medicare Shared Savings Program.” Although the proposed policy focuses on the Medicare Shared Savings Program, we would like to provide comments that recognize the impact on children’s hospitals that provide health care to the small number of children covered by Medicare and the large number covered by Medicaid. We also have questions about how this antitrust guidance would apply to the Pediatric Accountable Care Organization (ACO) demonstration, authorized under Section 2706 of the Patient Protection and Affordable Care Act (ACA).