It’s been some 47 days (and counting) since CMS released the Notice of Proposed Rule on Accountable Care Organizations. Initial reaction was somewhat subdued, given its inherent complexity. Yet recently it seems CMS’s likely surviving allies may be patient advocates, Medicare beneficiaries and the patchwork of provider culture associated with Federal program funding, as well as those tethered to or counting on the range of programs empowered by the Center for Medicare and Medicaid Innovation (CMMI).
Most recently that prevailing hedged if not ‘bearish sentiment’ was captured and parsed in a report compiled by HealthLeaders, perhaps best reflected in the lead quote from Chris Van Gorder, President and CEO, Scripps Health:
“Frankly, I was surprised. I thought there would be more carrots, not so much stick.”
Let’s back up a tad and re-set the context for this piece by recalling the ‘ACO Basics’ per recent preso compiled by Navigant, titled: ACO Proposed Regulations: Implications for Payers & Providers. In summary:
- CMS issued proposed rules for Medicare ACOs on 3/31/11 and is actively soliciting comments until June 6th, 2011.
- ACO refers to a group of providers and suppliers of services (e.g., hospitals, physicians, suppliers) that will work together to coordinate care for Medicare Part A & B patients.
- Implementation goal is January 1, 2012 (phase 1) and potentially July 1, 2012 (phase 2).
- Provider participation is voluntary; 5,000 patients minimum; 3-year contract between ACO & CMS; beneficiaries do not enroll in an ACO per se.
- CMS still reimburses FFS; CMS also develops benchmark against which ACO performance is measured to assess whether ACO qualifies for additional shared savings or is accountable for shared losses; 2 possible risk arrangement tracks.
- Extensive patient-centered criteria to demonstrate, i.e., Data reporting capabilities in place, Patient on the governing board, Systems to identify high-risk individuals, Processes for individualized care plans, Mechanisms for coordination of care (e.g., care coordinators) and Electronic exchange, summary of care in care transitions
“In the short-term, the ACO proposed rules will create a framework for the industry to start to transition from silos to a well-coordinated and aligned system.”
Industry leaders expect the regulations will be modified once CMS hears the volume of concerns during the comment period. And in the meantime, healthcare leaders are trying to do what the federal government wants in the long run, which is to cut costs, become more efficient and streamlined, and make tweaks or even massive changes in their systems to better manage all aspects of care for their patients.
To download and read the complete article, click here.
I may be reading too much into the buzz at the moment, but if you add up the documented concerns of industry leadership (both payor and provider verticals), you basically get the message of an industry saying ‘yes, but’. Yes, we agree with the ends, but at the moment we’re not quite convince by the ‘over-reach’ of the means. It’s perhaps the definition of ‘over-reach’ which seems to vary by camp that may be worthy of separate consideration. More later.
Meanwhile, today at 1:30 PM Eastern, CMS holds another listening session and conference call, more on that in a separate post.