ACO Comment Deadline Looming | December 3rd, 2010 by 5:30 PM (Eastern?)

Some key questions posed for input also providing context insight into current thinking at CMS relative to ACOs. Here they are direct from the ‘Medicare Program; Request for Information Regarding Accountable Care Organizations and the Medicare Shared Saving Program’ posted in Federal Register /Vol. 75, No. 221 /on Wednesday, November 17, 2010 / Proposed Rules.

Solicitation of Comments

As we develop our initial rulemaking for the Shared Savings Program and begin the development of potential models in the CMMI (CMS/Center for Medicare and Medicaid Innovation), we are seeking additional information, particularly from the physician community, on the following questions:

• What policies or standards should we consider adopting to ensure that groups of solo and small practice providers have the opportunity to actively participate in the Medicare Shared Savings Program and the ACO models tested by CMMI?

• Many small practices may have limited access to capital or other resources to fund efforts from which ‘‘shared savings’’ could be generated. What payment models, financingmechanisms or other systems might we consider, either for the Shared Savings Program or as models under CMMI to address this issue? In addition to payment models, what other mechanisms could be created to provideaccess to capital?

• The process of attributing beneficiaries to an ACO is important to ensure that expenditures, as well as any savings achieved by the ACO, are appropriately calculated and that quality performance is accurately measured. Having a seamless attribution process will also help ACOs focus their efforts to deliver better care and promote better health?  Some argue it is necessary to attribute beneficiaries before the start of a performance period, so the ACO can target care coordinationstrategies to those beneficiaries whose cost and quality information will be used to assess the ACO’s performance; others argue the attribution should occur at the end of the performance period to ensure the ACO is held accountable for care provided to beneficiaries who are aligned to it based upon services they receive from the ACO during the performance period. How should we balance these two points of view in developing the patient attribution models for the Medicare Shared Savings Program and ACO models tested by CMMI?

• How should we assess beneficiary and caregiver experience of care as part of our assessment of ACO performance?

• The Affordable Care Act requires us to develop patient-centeredness criteria for assessment of ACOs participating in the Medicare Shared Savings Program. What aspects of patient-centeredness are particularly important for us to consider and how should we evaluate them?

To review the complete request for information or comment online, click here.


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