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COVINGTON & BURLING LLP

VIII. PUBLIC COMMENT OPPORTUNITY

CMS has requested public comment on the proposed rule implementing the Program. Public comments must be received by June 6, 2011.

HHS has also requested public comments on the potential waiver of fraud and abuse laws as applied to the Program by June 6, 2011.

The IRS has requested comments on the proposed guidance regarding the status of 501(c)(3) organizations under the Program, also by May 31, 2011.

The FTC and DOJ have requested comments on their proposed Statement regarding ACOs, with no specified due date.

Anna Kraus

202.662.5320

akraus@cov.com

Demetrios Kouzoukas

202.662.5057

dkouzoukas@cov.com

Caroline Brown

202.662.5219

cbrown@cov.com

James Dean

202.662.5651

jdean@cov.com

Kevin Shortill

202.662.5113

kshortill@cov.com

Kate Sauser

202.662.5638

ksauser@cov.com

If you have any questions concerning the material discussed in this client alert, please contact the following members of our health care practice group:

This information is not intended as legal advice. Readers should seek specific legal advice before acting with regard to the subjects mentioned herein.

Covington & Burling LLP, an international law firm, provides corporate, litigation and regulatory expertise to enable clients to achieve their goals. This communication is intended to bring relevant developments to our clients and other interested colleagues. Please send an email to unsubscribe@cov.com if you do not wish to receive future emails or electronic alerts.

© 2011 Covington & Burling LLP, 1201 Pennsylvania Avenue, NW, Washington, DC 20004-2401. All rights reserved.

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