AHA pushes CMS for flexibility on ACOs
In a letter last week to Jonathan D. Blum, deputy director of the Centers for Medicare and Medicaid Services (CMS), the American Hospital Association (AHA) asked for clarity on accountable care organization (ACO) implementation and cost savings for healthcare delivery, particularly in Medicare.
“AHA is pleased to offer our comments on the development and implementation of [ACOs], as described in Section 3022 of the Patient Protection and Affordable Care Act [PPACA], the Medicare Shared Savings Program,” wrote Linda E. Fishman, senior vice president of the Washington, D.C.-based hospital lobbying group.
"The [PPACA] allows for considerable flexibility in which providers may organize as ACOs. We believe CMS should allow different configurations of provider organizations to enter the shared savings program to see what works and what does not work well,” the letter stated.
The AHA listed seven “must-haves” and three “must-not-haves” as part of ACO implementation. The must-haves include:
Among the must-not-haves listed in the letter are:
The full text of the AHA’s letter can be found here.
“AHA is pleased to offer our comments on the development and implementation of [ACOs], as described in Section 3022 of the Patient Protection and Affordable Care Act [PPACA], the Medicare Shared Savings Program,” wrote Linda E. Fishman, senior vice president of the Washington, D.C.-based hospital lobbying group.
"The [PPACA] allows for considerable flexibility in which providers may organize as ACOs. We believe CMS should allow different configurations of provider organizations to enter the shared savings program to see what works and what does not work well,” the letter stated.
The AHA listed seven “must-haves” and three “must-not-haves” as part of ACO implementation. The must-haves include:
- Spending and quality targets by which the ACO’s performance must be judged;
- Prospective payment adjustments for such factors as graduate medical education costs; and
- Waivers of what the AHA called five major regulatory “barriers” that govern relationships between providers and how incentives are used to change care delivery.
Among the must-not-haves listed in the letter are:
- Rigid organizational/governance rules that could inadvertently act as barriers to many providers;
- Rules on the distribution of shared savings within an ACO: “Building the necessary relationships within an ACO will require a great deal of flexibility to ensure that performance targets are met”; and
- Rules on specific services that must be provided directly by the ACO, other than adequate primary care capacity as required by the PPACA. “The resources available in any given community differ. ACOs will have strong incentives to build the relationships necessary to have as many of the needed services delivered within the ACO. Rigidity in this area of the rules could pose barriers to ACOs, especially in rural areas,” the letter stated.
The full text of the AHA’s letter can be found here.