Written by: Neda Mirafzali, Esq. and Kathryn Hickner-Cruz, Esq.The Health Law Partners, P.C., Southfield, MIIn the Summer 2011 issue of the Communique, we analyzed the then-new Medicare Shared Savings Program (“MSSP”) accountable care organization (“ACO”) proposed rule (“Proposed Rule”) (issued by the Centers for Medicare and Medicaid Services (“CMS”) on April 7, 2011) as it related to anesthesiologists. At that time, physicians’ desire for involvement in the MSSP (which was born as part  of President Obama’s healthcare reform law) was bleak, at best.  The Proposed Rule introduced barrier after barrier after barrier that left the medical community disappointed and angry.  Anesthesiologists were left with no clear understanding of the role they would play in the new push for better care for individuals, better health for populations, and lower growth in expenditures—CMS’ three-part aim for ACOs.  Anesthesiologists were dubious as to whether they would actually enjoy a piece of the Medicare shared savings...