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Analysis of Policy Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations* Section 2706 of the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 ("PPACA" or the "Act") authorizes physicians, hospitals and other health care providers to form Accountable Care Organizations ("ACOs") to work together to manage and coordinate care for Medicare beneficiaries for purposes of the Act's Medicare Shared Savings Program. Under that program, participating providers meeting certain criteria defined by the Centers for Medicare and Medicaid Services ("CMS") may qualify to share savings they create under the Medicare program. Given the time and resources required to form and operate ACOs, however, it is anticipated that

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