Scott Strickland
speaker
283 appearances
1 recordings
1 series
first heard Jun 2026
last heard 30 Jun
Scott Strickland’s voice in public audio — every appearance, attributed to the second.
Trend
recordings per month · last 12 monthsRecordings per month over the last 12 months — 1 in all, peaking in Jun 2026 with 1.
Appearances
42 CFR Part 425.
And so everything really, of course, there's sub-regulatory guidance as well, but really like the rules of the road are in that part of the CFR.
So for a innovation center program such as the REACH ACO program or the new LEAD model, which we'll talk about in a minute, that is really a kind of a
continuation of reach.
There are no regs.
And so because they didn't have to go through rule making in order to um roll the model out.
And so what there is is a um giant participation agreement between CMS and the ACO that contains a lot of the um rules, if you will, of the program.
That's the main source of truth.
There's also, I think, other documents that are very, very important and
instructive um in terms of just educating yourselves on
How the program works.
And for instance, like the RFA, the request for applications for a program like this is gonna be clocking in at well over a hundred pages.
And that is like a great source of information.
But uh to answer your question, I mean, for me, one of the main differences is um it's implemented via contract rather than regged.
I think another difference along those because of that is that
CMMI has
I'm sure you've seen this, Neil, in your practice, but you know, CMMI just has more flexibility to make changes midstream during the program because they don't have to go through rulemaking.
And so that can be uh, and they've done that quite a bit with REACH, for instance, where every year there'll be some changes that they're announcing through really amendments to.
That participation agreement.
And they don't have to go through rulemaking.
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