Identify the federal law (or laws) that would be waived by the specific waiver on which the ACO and its participants intend to rely. Explain what is prohibited by that law (or laws), and explain how the proposal could violate that law (or laws) in the absence of a waiver.
Summarize the requirements that must be met to qualify for the specific waiver.
Analyze whether the proposal meets all of the requirements for the specific waiver. State the arguments (if any) for concluding that the proposal meets all of those requirements, as well as the arguments (if any) for concluding that the proposal does not meet them. Be sure to state your conclusion and explain the basis for it.
As a matter of policy, explain whether you think that the requirements for that specific waiver should be changed by the secretary of HHS. Specifically, should the secretary amend the requirements for that specific waiver to balance the goal of beneficiary