By Gregg A. Masters, MPH
The ‘signal to noise’ discernment premium went up a notch recently with the following tweet:
@NCQA Read more about newly recognized ACO @KelseySeybold and their commitment to quality and value in the Houston Chronicle http://ow.ly/g6vzl 7:39 AM – 14 Dec 12
And with that breaking news announcement (Kelsey Seybold is the first ACO to be recognized by NCQA) another piece of the ACO puzzle has been laid before American public as well as industry stakeholders. Unfortunately one cannot simply graft the information on top of an expanding but orderly base of journalistic reporting and therefore public assimilation of how their healthcare experience can be expected to change. The fast developing (i.e., ‘bottoms up’, vs. alleged ‘top down’ dictates of an overreaching Federal overlord) world of ACOs are just not that simple to grasp due to the underlying absence of operating standards, the best intentions of Government and the private sector notwithstanding.
A closer look reveals some of the unintentional misdirect or potential for market confusion. The referenced Houston Chronicle article (aka @HoustonChron) erroneously identifies the NCQA as:
…the entity that certifies ACOs.
Yet, NCQA (the National Committee on Quality Assurance) is a ‘private non-profit healthcare measurement group’ based in Washington, D.C. that has organized a voluntary, fee based ‘ACO accreditation program.’ NCQA’s ‘ACO standards’ focus on the following seven core competencies:
- ACO Structure and Operations
- Access to Needed Providers
- Patient-Centered Primary Care
- Care Management
- Care Coordination and Transitions
- Patient Rights and Responsibilities
- Performance Reporting and Quality Improvement
For context, private, nongovernmental entities typically recognize submitting applicants via a certification or ‘accreditation’ consideration process that approximates a ‘good housekeeping’ or ‘JD Power’ like ‘seal of approval’. They do not license nor legally certify ACOs per se, unless that authority is delegated to them by some governmental entity.
The authority that officially ‘certifies’ ACOs as legal entities for participation in the Medicare Shared Saving Program (MSSP) is the Center for Medicare and Medicaid Services (CMS), aka @CMSgov. ACOs are codified in Section 3022 of the Affordable Care Act and serve as the principal market based vehicles to fulfill the goals of the Medicare Shared Savings Program.
Even here though, the story is not that straightforward, as CMS certifies entities for participation in the MSSP, while its innovation arm, a division within CMS, the Center for Medicare and Medicaid Innovation (CMMI) aka @CMSinnovates, both admits and ‘certifies’ participation in the ‘Pioneer Program’.
Splitting hairs? Maybe. But there are structural differences of what constitutes an ACO to the Feds vs. NCQA vs. those effectively deemed an ACO via contractual agreements with one of more payers under the terms of an ‘accountable care collaboration’ or derivative arrangement.
So perhaps the correct narrative is that NCQA is ‘an’ entity that certifies some ACOs, not ‘the’ entity per se. More accurately though and per terms of their program, NCQA ‘accredits’ ACOs (as defined by NCQA) via a seal that signifies:
Organizations that earn accreditation may have extra credibility and first-mover advantages in their local markets. Being an early adopter of ACO accreditation may also help an organization become eligible to participate in demonstration projects or pilot programs that public and private health plans sponsor.
Finally, it’s interesting to note, that Kelsey Seybold Clinic though now recognized by NCQA is neither participating in MSSP, nor as a risk savvy medical group, perhaps even integrated delivery system, in the Pioneer Program designed and administered by CMMI for more advanced risk bearing participants.
So you be the judge. The slog continues?
Excellent commentary and point by point review of the misconception that there is an ACO certifying body.
Thanks James! I appreciate the sentiment. In fact, I love your suggestion, and have modified the title to: ‘More or Less Confusion in the ACO World: Who Really Certifies ACOs’.
Gregg, Very good analysis. NCQA claiming that it certifies ACOs is akin to my dog HoneyBear ( https://twitter.com/WorldsCutestDog ) setting up an ACO certification.
We saw this a decade ago when NCQA, JCAHO, and URAC all set up accreditation programs for disease management. This is a turf war among non-profits staking out the newest discovered lands.
Indeed Vince. Seems like we’ve been here before, with this quasi public/private attempt to promote institutional quality and enhance safety. Despite the Joint Commission’s relentless oversight and seals of approvals issued, ‘hospital acquired infections’ (aka ‘iatrogenic medicine’) the ‘stable’ run rate = 1.7 million/year in U.S. (see: http://www.consumerreports.org/cro/2012/12/deadly-infections/index.htm).
Also see conclusion from: ‘A decade of prevalence surveys in a tertiary-care center: trends in nosocomial infection rates, device utilization, and patient acuity.”
Despite apparent increases in the severity of illness of our patients, overall rates of nosocomial infection remained stable during a decade of study. Rates of nosocomial bloodstream infection increased, in parallel with National Nosocomial Infection Surveillance System data. We found repeated prevalence surveys to be useful in following trends and rates of infection, device utilization, and abnormal laboratory values among patients at our institution. Such methodologies can be valuable and low-cost components of a comprehensive infection surveillance, prevention, and control program and other potential quality-improvement initiatives, because they enable better annual planning of departmental strategies to meet hospital needs.
Gregg, I enjoyed reading this helpful article and detailed artical. I also manage a blog outlining the ups and downs of ACO’s and would be extremely grateful for any comments you might have for my articles. Thank you and I look forward to reading your next post.
Thanks Rosa, will take a look!
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