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Accountable Care Organizations: Perspectives on the Proposed Rule

Accountable Care Organizations: Perspectives on the Proposed Rule. Susan DeVore President and CEO May 13, 2011. Working toward population health. Population total value. Systematic improvement (Inpatient/outpatient value). Process Improvement (Evidence-Based Care).

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Accountable Care Organizations: Perspectives on the Proposed Rule

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  1. Accountable Care Organizations:Perspectives on the Proposed Rule Susan DeVore President and CEO May 13, 2011

  2. Working toward population health Population total value Systematic improvement (Inpatient/outpatient value) Process Improvement(Evidence-Based Care)

  3. 42 States redesigning care

  4. What we like • Timely data from CMS: (A,B, and D data as often as monthly) • CMS and ACOs educating beneficiaries • Multiple payment models • Consensus-based measures • Clinically integrated for anti-trust purposes • Safe harbor under anti-kickback and CMP • Anti-trust safety zones and 90 day expedited advisory opinion process

  5. Priority payment issues • Model with no downside risk: In both of the proposed models, hospitals must accept two-sided risk. Only some of our members are prepared to take that risk. We also believe that CMS should reduce the 25% withhold in the two-sided model and eliminate it if there is an option without risk. • Higher shared savings: CMS should reconsider its savings split to share back 70-80%of the total in preliminary years of the program, instead of 52.5/65%, or adjust the confidence interval requirement. • Capitation: While CMS does propose multiple payment models, it does not include a partial capitation model. We encourage this be offered either through the program or the Center for Medicare and Medicaid Innovation.

  6. Priority issues with standards, incentives and risk • Quality measures: Reduce the proposed 65 measures and 50% primary care meaningful use requirements. • Value-added services: Expand beneficiary communications and services including: pay for travel, technologies, seminars, co-pay waivers, etc. • Risk adjustment: Allow the ACO risk score to grow rather than holding it constant to the baseline period. • Legal waivers: Support waiving Stark, anti-kickback and CMP laws for distributions of shared savings, but ACOs should be allowed broader exceptions for specialists not part of the ACO. • Calculations:Exclude add-ons such as IME and DSH as well as wage adjust the benchmarks and expenditures as these factors cannot be affected and are unrelated to care transformation.

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