Question to answer: PROVIDE examples of key "talking points" that she should AVOID speaking about and reasons why she should avoid speaking about them.

Situation: You are the chief operating officer of a tax-exempt community hospital with approximately $400 million in annual revenue. The CEO has informed you that she is about to begin negotiations with a for-profit medical group, with over 300 physicians, to form an accountable care organization that would participate in the Medicare Shared Savings Plan. The ACO will be formed as an LLC (i.e., neither a partnership nor a corporation). The hospital may be asked to invest up to $6 million in the ACO. She wants to make sure that the hospital's tax exemption will not be jeopardized on account of this arrangement. The CEO is an inquisitive person, so merely citing IRS guidance ("the reason is that the IRS says so") is not likely to please her. She will want to know why. She has retained legal counsel with regard to complying with the Medicare rules in forming an ACO, so you may ignore that issue and concentrate on the tax issues.