Cerney, who responded to HealthLeaders Media via email, says, "ACOs can qualify under 501(c)(3) if they are certified and meet the standards of CMC; approximately 89 have been so certified. I have not seen any rulings by the IRS as of yet."
Also, finance leaders may want to alert their governing boards to pay particular attention to 501(c)(r) as it deals with improving transparency in transactions. The IRS will be looking to see that boards are doing a thorough due diligence when reviewing transactions, especially as they relate to the community health needs assessment, financial assistance policies, billing and collections, and limitations on charges for medical care.
"We are awaiting the 501(c)(r) regulations. The IRS is issuing guidance and I expect to see a rapid increase of IRS announcements following the Supreme Court Decision," notes Cerny.
In addition to Cerny, four representatives from the accounting and consulting firm Moss Adams, LLP offered their thoughts via email.