After reading the final rule for Medicare Accountable Care Organizations (ACOs), one might conclude that the IT infrastructure needed to support an ACO is too daunting to build. CMS alludes to dozens of technological documents and processes in the rule, including electronic health records (EHRs), personal health records (PHRs), telehealth, health information exchanges (HIEs), data warehousing, analytics, and member registries. The resulting ACO IT platform would involve a very complex and expensive implementation. In fact, Medicare’s estimate of $1.75 million for ACO infrastructure is a low estimate for most healthcare organizations. Healthcare organizations are likely to spend many times that amount to properly implement all the IT elements envisioned for Medicare ACOs. Furthermore, since implementing this type of ACO platform would require technology not readily available in the present marketplace, a considerable amount of custom development would also be needed.