Meeting of the Advisory Panel on Outreach and Education (APOE) Centers for Medicare and Medicaid Services March 27, 2013.

Size: px
Start display at page:

Download "Meeting of the Advisory Panel on Outreach and Education (APOE) Centers for Medicare and Medicaid Services March 27, 2013."

Transcription

1 701 Pennsylvania Avenue, Ste. 800 Washington, DC Tel: Fax: Meeting of the Advisory Panel on Outreach and Education (APOE) Centers for Medicare and Medicaid Services March 27, 2013 Statement of Ann-Marie Lynch Executive Vice President Payment and Health Care Delivery The Advanced Medical Technology Association Good morning. My name is Ann-Marie Lynch and I am speaking on behalf of the Advanced Medical Technology Association or AdvaMed. We appreciate the opportunity to participate in today s meeting of the Advisory Panel on Outreach and Education. Your recommendations to the Secretary and to the CMS Administrator to enhance the effectiveness of consumer education strategies could lead to significant improvements for individuals enrolled in these programs. This panel has an important opportunity and I commend you for your service on this committee. My comments today will focus on the Medicare program and recent changes that will establish new health delivery models for beyond the traditional fee-for-service program and Medicare Advantage plans. The Affordable Care Act included several health care delivery reforms designed to improve efficiency and the quality of care provided to Medicare beneficiaries. AdvaMed supports these goals and believes that medical technology is a key component in achieving them. Two programs in particular, Accountable Care Organizations and the Bundled Payment Initiative, will significantly impact Medicare beneficiaries and the care received from their providers. Bringing innovation to patient care worldwide

2 ACOs and Bundled Payments are intended to lower costs and provide higher quality care by changing payment incentive structures to foster greater cooperation and coordination among providers. However, incentives in these programs to reduce spending could have the inadvertent effect of compromising patient access to the full array of treatment options, and discouraging the use of innovative treatments. These new ACO and Bundling Payment programs will lead to significant changes in the operating structure of hospitals, physician practices, and health care systems. These programs allow many new hospital/physician arrangements and offer significant financial incentives for participating physicians and hospitals, incentives that were previously prohibited by the Stark physician self-referral law, the Federal anti-kickback statute, and the civil monetary penalty laws. The key concern here is that health care entities, physicians, and other practitioners could structure their financial relationships simply to cut costs and enhance profit margins without regard to quality improvement and coordination of care. Expanding the waiver authority opens the door to activity that presents a significant risk of patient abuse. Medicare beneficiaries need to be fully informed about all aspects of these new programs. In addition, the impact of such significant changes on Medicare beneficiaries and, relatedly, their access to care, should be carefully monitored and reported to the public. Accountable Care Organizations (ACOs): CMS approved three waves of applications for providers to participate in the Medicare Shared Savings Program (MSSP) for ACOs program two in April and July of 2012 and a third in January Two other ACO programs were initiated by the Center for Medicare & Medicaid Innovation (CMMI) and include the Pioneer ACO Model, which is designed for organizations having experience in integrated care delivery, and the Advanced Payment Model, which is designed for rural and physician-based ACOs needing start-up resources for building care coordination infrastructure. ACOs have a primary care focus, with providers held accountable for the quality, cost and overall care of assigned Medicare beneficiaries. They may 2

3 be group practices, networks of physicians, acute care hospitals employing physicians, partnerships or joint ventures between hospitals and physicians, and federal health centers. Each ACO has a spending target or benchmark which is then compared to actual spending by the Medicare program for these beneficiaries. If ACO spending in a year is below the target established for that period, and the ACO participants meet certain quality standards, the ACOs may keep a portion of the savings. For large ACOs, the savings could be in the millions of dollars and physicians and other providers will receive significant cash payments for reducing the amount and/or type of services billed to Medicare. A total of 250 organizations are now participating in these three ACO programs, and they are serving 4 million beneficiaries. That s about 9 percent of Medicare beneficiaries. While Medicare beneficiaries choose to enroll in fee-for-service or a Medicare Advantage plan, their participation in an ACO is quite different. In the case of an ACO, it is the primary care doctor, internist, or geriatrician who decides to enroll in an ACO. The practitioner then informs the beneficiary of her choice. If a beneficiary begins to understand the potential implications of the financial incentives allowed in the ACO model and is concerned that the significant financial incentives may impact the care he receives from his physician or referrals to specialists, he must find a new doctor. Bundled Payments. In January, the new CMS Innovation Center (CMMI) announced that it was moving forward with its large scale bundled payment initiative by testing four different bundled payment models that cover various service categories. All four models in the Initiative will be episode-based, and the episodes used in each of the models will be triggered by a hospitalization. If doctors and hospitals reduce spending below a target, hospitals or post-acute care providers may again share up to 50 percent more than the amount that Medicare otherwise would pay for services. Model 1 with 32 hospital awardees will begin as early as April The other three models will begin July 1, 2013, with over 100 participants partnering with over 400 hospitals and other providers. Again, these models introduce considerable changes to the delivery of health care in the ability of providers to provide financial incentives to reduce Medicare expenditures. Under the bundled payment initiatives, participants may receive up to 50 percent of the amount of payments they would have otherwise received from Medicare. A 3

4 physician who bills Medicare $150,000 in a year could potentially receive an additional $75,000 from a hospital in the bundled payment program if that physician helped to reduce the amount and/or type of services provided to her patients, thus reducing Medicare expenditures. Within the Bundled Payment program, there are incentives to use less expensive therapies which may not be optimal for patient. If reductions in spending are the result of reduced readmissions, better scheduling and streamlining of care, less duplication of tests, improved coordination and discharge planning, better hand washing, and reduced infections, care will improve and Medicare beneficiaries will benefit. However, ACO and Bundled Payment participants could reduce Medicare costs to stay below their benchmark or target by stinting on care. In this case, patient care will be compromised. What key information should a Medicare beneficiary receive? What types of questions should be answered? For example: Will the pressure to reduce Medicare spending within an ACO and or Bundled Payment Initiative, result in compromised care? What happens when this pressure is complicated by significant financial incentives, previously prohibited by law? Will patients experience delays in or denials of access to services? Will patients see fewer referrals to specialists? Will Medicare patients with more complex needs or chronic issues receive the level of care they need with such strong incentives to reduce costs? And will they understand that some of these changes might be directly related to the financial incentives contained in the delivery reform models? The rules have changed and beneficiaries and other patients need to know it. This panel has the opportunity to make a meaningful difference through outreach and education. Medicare & You Handbook: Medicare beneficiaries should be fully informed of the potential benefits and implications of new incentives under the ACO programs. The 140-page Medicare & You handbook includes just two short paragraphs on page 126 with very limited information. While Medicare beneficiaries are directed to a website address {www.medicare.gov/acos.html) with additional guidance., the information on the CMS website is limited and does not fully inform beneficiaries about the risk of the potential for stinting on care, though the site promotes the ACO program. 4

5 Recommendations: Beneficiaries should receive balanced information that fully explains the benefits and concerns associated with receiving care from ACO and Bundled Payment providers, including the potential negative impact of the financial incentives on patient care. Beneficiaries should receive clear information about two distinct decisions they must make. First, whether they will see an ACO participating primary care physician (including a geriatrician, internist, etc.) or move to another primary care doctor who is not tied to an ACO, and second, whether they will decline to share their identifiable claims data with their ACO. A complete listing of ACO and Bundled Payment program participating primary care physicians, and other practitioners should be readily available on the CMS website. Each ACO or Bundled Payment participant, as a condition of participation, should be required to inform the public of the amount of shared savings payments received by each practitioner or provider. Limits of Quality Measures: ACO and Bundling programs rely on reported quality measures to ensure that patient care is not compromised under these new delivery models. Yet these quality measures are limited in scope, may not keep pace with advances in available treatments, and are mostly process measures rather than outcomes measures. For example, the ACO program requires participants to meet certain levels on 33 quality measures yet there are no measures for cancer treatment, major heart procedures, orthopedic procedures or neurological conditions. Beneficiaries should be informed of the limitations in these quality measures and should also understand the limitations in what an ACO or bundled payment quality score can say about quality of care actually received. 5

6 Recommendations: The quality scores for each ACO and Bundled Payment participant should be readily available on the CMS website and on the websites of participating ACO and Bundling providers and practitioners. It is also imperative that quality measures be updated or modified frequently to keep pace with medical advances. Without proper adjustments to the quality measurements used to calculate an ACO s shared savings, physicians could be penalized for being early adopters of new treatment options and providing patients the best options. Finally, the most clear and direct method to determine if Medicare beneficiaries are fully informed about the benefits and potential concerns with these new delivery models is to ask them. An independent survey comparing Medicare beneficiaries whose providers are participating in an ACO or Bundled Payment program to Medicare beneficiaries whose providers are not participating in an ACO or bundled payment program could provide meaningful information. Recommendation: The Secretary should conduct a survey assessing Medicare beneficiaries experiences with the new ACO and bundled payment models compared to other Medicare enrollees. The survey should assess beneficiaries understanding of these programs including the quality measures and the significant financial rewards available to their providers for reducing Medicare expenditures. Referrals to specialists, delays in care, and substitution of services should also be examined. The draft survey questions should be available to the public for feedback and results of the survey should be available to the public. Thank you for this opportunity to share these recommendations with you. We look forward to working with you. 6

THE EVOLUTION OF CMS PAYMENT MODELS

THE EVOLUTION OF CMS PAYMENT MODELS THE EVOLUTION OF CMS PAYMENT MODELS December 3, 2015 Dayton Benway, Principal AGENDA Legislative Background Payment Model Categories Life Cycle The Models LEGISLATIVE BACKGROUND Medicare Modernization

More information

Crowe Healthcare Webinar Series

Crowe Healthcare Webinar Series New Payment Models Crowe Healthcare Webinar Series Audit Tax Advisory Risk Performance 2014 Crowe Horwath LLP Agenda Bundled Care for Payment Improvements Payment Models Accountable Care Organizations

More information

AHLA. BB. Accountable Care Organizations and the Medicare Shared Savings Program. Troy Barsky Crowell & Moring LLP Washington, DC

AHLA. BB. Accountable Care Organizations and the Medicare Shared Savings Program. Troy Barsky Crowell & Moring LLP Washington, DC AHLA BB. Accountable Care Organizations and the Medicare Shared Savings Program Troy Barsky Crowell & Moring LLP Washington, DC Daniel F. Murphy Bradley Arant Boult Cummings LLP Birmingham, AL Terri L.

More information

Mar. 31, 2011 (202) 690-6145. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Mar. 31, 2011 (202) 690-6145. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Room 352-G 200 Independence Avenue, SW Washington, DC 20201 Office of Media Affairs MEDICARE FACT SHEET FOR IMMEDIATE RELEASE

More information

Accountable Care Organizations An Operational Overview

Accountable Care Organizations An Operational Overview Accountable Care Organizations An Operational Overview Chris Champ Principal cchamp@eidebailly.com 701-239-8620 1 Medicare Spending 2 1 CMS Goal Transition of Risk 60 50 40 30 20 10 0 2015 2016 2018 Percentage

More information

Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices

Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices Accountable Care Organizations & Other Reimbursement Reforms: The Impact on Physician Practices Martin Bienstock, Esq. Wilson Elser Martin.Bienstock@WilsonElser.com The New York Times Take... For the first

More information

Look Before You Leap: Legal and Practical Obstacles with ACOs

Look Before You Leap: Legal and Practical Obstacles with ACOs Look Before You Leap: Legal and Practical Obstacles with ACOs Houston ACO Conference May 7, 2013 Edward Vishnevetsky, Esq. Coordinated Care and ACOs Coordinated Care Goal: ensure that healthcare providers

More information

See page 16. Thomas A. Vallas

See page 16. Thomas A. Vallas Compliance TODAY July 2014 a publication of the health care compliance association www.hcca-info.org What s the key to successfully merging two large hospital systems? an interview with Michael R. Holper

More information

KATHLEEN L. DEBRUHL & ASSOCIATES, L.L.C. 614 TCHOUPITOULAS STREET NEW ORLEANS, LOUISIANA 70130 504.522.4054 (OFFICE) 504.522.9049 (FAX) WWW.MD-LAW.

KATHLEEN L. DEBRUHL & ASSOCIATES, L.L.C. 614 TCHOUPITOULAS STREET NEW ORLEANS, LOUISIANA 70130 504.522.4054 (OFFICE) 504.522.9049 (FAX) WWW.MD-LAW. CMS RELEASES PROPOSED ACCOUNTABLE CARE ORGANIZATION REGULATIONS By: Kathleen L. DeBruhl, Esq. and Lindsey E. Surratt, Esq. On March 31, 2011, the Centers for Medicare and Medicaid Services ( CMS ) issued

More information

Legal & Policy Issues Related to ACO Formation by Independent Physician Groups

Legal & Policy Issues Related to ACO Formation by Independent Physician Groups Legal & Policy Issues Related to ACO Formation by Independent Physician Groups Troy Barsky Arthur Lerner Crowell & Moring LLP America s Health Insurance Plans ACO Summit May 15, 2013 Background Government

More information

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS Briefing Paper on the Proposed Medicare Shared Savings Program The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to implement

More information

CMS ACO Proposed Regulations

CMS ACO Proposed Regulations CMS ACO Proposed Regulations May 2011 Proposed CMS ACO Regulations Proposed Regulations issued March 31, 2011 Comments due back June 6, 2011 Requires 3 year binding commitment Formal Legal Structure Required

More information

Marilyn Tavenner Administrator Centers for Medicare and Medicaid Services Attention: CMS-1612-FC 7500 Security Blvd Baltimore, MD 21244

Marilyn Tavenner Administrator Centers for Medicare and Medicaid Services Attention: CMS-1612-FC 7500 Security Blvd Baltimore, MD 21244 February 6, 2015 Marilyn Tavenner Administrator Centers for Medicare and Medicaid Services Attention: CMS-1612-FC 7500 Security Blvd Baltimore, MD 21244 RE: Medicare Program; Medicare Shared Savings Program:

More information

THE LANDSCAPE OF MEDICAID ALTERNATIVE PAYMENT MODELS

THE LANDSCAPE OF MEDICAID ALTERNATIVE PAYMENT MODELS POLICY BRIEF September 2014 THE LANDSCAPE OF MEDICAID ALTERNATIVE PAYMENT MODELS Authored by: America s Essential Hospitals staff KEY FINDINGS States have increasingly sought to establish alternative payment

More information

2010 MHA Governance Leadership Forum: Accountable Care Organizations. Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan

2010 MHA Governance Leadership Forum: Accountable Care Organizations. Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan 2010 MHA Governance Leadership Forum: Accountable Care Organizations Chris Rossman, Esq. Foley & Lardner LLP Detroit, Michigan Overview Major health care payment reform under the Affordable Care Act (

More information

January 3, 2012. RE: Comments submitted at http://www.regulations.gov.

January 3, 2012. RE: Comments submitted at http://www.regulations.gov. January 3, 2012 RE: Comments submitted at http://www.regulations.gov. Marilyn Tavenner, Acting Administrator U.S. Department of Health and Human Services Centers for Medicare and Medicaid Services Attention:

More information

How Health Reform Will Affect Health Care Quality and the Delivery of Services

How Health Reform Will Affect Health Care Quality and the Delivery of Services Fact Sheet AARP Public Policy Institute How Health Reform Will Affect Health Care Quality and the Delivery of Services The recently enacted Affordable Care Act contains provisions to improve health care

More information

Accountable Care Organizations: What Providers Need to Know

Accountable Care Organizations: What Providers Need to Know DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Accountable Care Organizations: FACT SHEET Overview http://www.cms.gov/sharedsavingsprogram On October 20, 2011, the Centers

More information

Critical Access Hospitals and

Critical Access Hospitals and Critical Access Hospitals and Health Care Reform What s in it for you? Patient Protection and Affordable Care Act (ACA) Fundamental changes Moving Medicare from payment for services to payment for outcomes

More information

CMS Innovation and Health Care Delivery System Reform

CMS Innovation and Health Care Delivery System Reform CMS Innovation and Health Care Delivery System Reform Dr. Patrick Conway, M.D., MSc CMS Chief Medical Officer and Deputy Administrator for Innovation and Quality Director, Center for Medicare and Medicaid

More information

1. Would additional health care organizations be interested in applying to the Pioneer ACO Model? Why or why not?

1. Would additional health care organizations be interested in applying to the Pioneer ACO Model? Why or why not? February 28, 2014 Re: Request for Information on the Evolution of ACO Initiatives at CMS AMGA represents multi specialty medical groups and other organized systems of care, including some of the nation

More information

December 3, 2010. Dear Administrator Berwick:

December 3, 2010. Dear Administrator Berwick: Donald Berwick, M.D. Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20201

More information

DRAFT NCMS POLICY (v. 7) Accountable Care Organizations

DRAFT NCMS POLICY (v. 7) Accountable Care Organizations DRAFT NCMS POLICY (v. 7) Accountable Care Organizations Background: Accountable Care Organizations (ACOs) are an emerging health care delivery model comprised of groups of providers that join together

More information

DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM

DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM 1 DETAILED SUMMARY--MEDCIARE SHARED SAVINGS/ACCOUNTABLE CARE ORGANIZATION (ACO) PROGRAM Definition of ACO General Concept An ACO refers to a group of physician and other healthcare providers and suppliers

More information

The Regulations Are Out: Is An ACO Right For You? Moderator David Pursell 816.983.8190 david.pursell@huschblackwell.com

The Regulations Are Out: Is An ACO Right For You? Moderator David Pursell 816.983.8190 david.pursell@huschblackwell.com The Regulations Are Out: Is An ACO Right For You? Moderator David Pursell 816.983.8190 david.pursell@huschblackwell.com Today s Discussion Overview of the ACO Regulations Alternatives to a Medicare ACO

More information

November 22, 2010. RE: File code CMS-1345-NC. Dear Dr. Berwick:

November 22, 2010. RE: File code CMS-1345-NC. Dear Dr. Berwick: 601 New Jersey Avenue, N.W. Suite 9000 Washington, DC 20001 202-220-3700 Fax: 202-220-3759 www.medpac.gov. Glenn M. Hackbarth, J.D., Chairman Robert A. Berenson, M.D., F.A.C.P., Vice Chairman Mark E. Miller,

More information

What is an Accountable Care Organization. Amit Rastogi, MD President/CEO PriMed

What is an Accountable Care Organization. Amit Rastogi, MD President/CEO PriMed What is an Accountable Care Organization Amit Rastogi, MD President/CEO PriMed Goals Why is U.S. healthcare undergoing dramatic change How reimbursement structures are likely to change What is the timeline

More information

Summary of Final Rule Provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Summary of Final Rule Provisions for Accountable Care Organizations under the Medicare Shared Savings Program DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Summary of Final Rule Provisions for Accountable Care Overview The Centers for Medicare & Medicaid Services (CMS), an agency

More information

Fraud & Abuse Waivers Under the Medicare Shared Savings Program

Fraud & Abuse Waivers Under the Medicare Shared Savings Program Fraud & Abuse Waivers Under the Medicare Shared Savings Program Robert G. Homchick Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program

NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS. Briefing Paper on the Proposed Medicare Shared Savings Program NATIONAL ASSOCIATION OF COMMUNITY HEALTH CENTERS Briefing Paper on the Proposed Medicare Shared Savings Program The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule to implement

More information

Accountable Care Organization Refinement Brief

Accountable Care Organization Refinement Brief Accountable Care Organization Refinement Brief The participants in the Medicare Shared Savings Program (MSSP), the Physician Group Practice Transition Demonstration (PGP-TD), and the Pioneer Accountable

More information

Medicare Accountable Care Organizations: What it s about

Medicare Accountable Care Organizations: What it s about Medicare Accountable Care Organizations: What it s about Gail Albertson, MD Associate Professor of Medicine Chief Operating Officer, UPI Medicare Accountable Care Under the Medicare Shared Savings Program

More information

Accountable Care and Value Based Payments 101: Government Programs Update

Accountable Care and Value Based Payments 101: Government Programs Update 1 Accountable Care and Value Based Payments 101: Government Programs Update June 24 th, 2014 Dave Neiman, FSA, MAAA Senior Consulting Actuary DaveN@Wakely.com (720) 226-9806 2 Caveats Opinions expressed

More information

RE: CMS-1416-P, Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule

RE: CMS-1416-P, Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule Marilynn B. Tavenner Administrator Center for Medicare & Medicaid Services U.S. Department of Health and Human Services Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC

More information

Legal Challenges and Concerns with Clinical Integration

Legal Challenges and Concerns with Clinical Integration Legal Challenges and Concerns with Clinical Integration By Edward Matto and Claire Turcotte, Bricker & Eckler LLP A clear goal of health reform is to foster greater integration and collaboration among

More information

Alternative Payment Mechanisms in the Next Generation ACO Model

Alternative Payment Mechanisms in the Next Generation ACO Model 2016 Alternative Payment Mechanisms in the Next Generation ACO Model UPDATED MAY 2016 AMERICAN HEALTH CARE ASSOCIATION 1201 L ST NW WASHINGTON DC 20005 (202)842-4444 INTRODUCTION This document provides

More information

August 12, 2010. Dear Dr. Berwick:

August 12, 2010. Dear Dr. Berwick: Donald M. Berwick, MD Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services 200 Independence Avenue, SW Room 314G Washington, DC 20201 Dear Dr. Berwick: I am

More information

Bundle Care Care Tool Affordable Insurance Exchanges

Bundle Care Care Tool Affordable Insurance Exchanges See attached resources for further information about the Health Care Reform buzz words for 2013. Bundle Care Care Tool Affordable Insurance Exchanges CMS - Bundled Payments for Care Improvement Initiative

More information

U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON ENERGY AND COMMERCE

U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON ENERGY AND COMMERCE U.S. HOUSE OF REPRESENTATIVES COMMITTEE ON ENERGY AND COMMERCE April 15, 2016 TO: FROM: Members, Subcommittee on Health Committee Majority Staff RE: Hearing entitled Medicare Access and CHIP Reauthorization

More information

Newsroom. The quality measures are organized into four domains:

Newsroom. The quality measures are organized into four domains: Newsroom People with Medicare will be able to benefit from a new program designed to encourage primary care doctors, specialists, hospitals, and other care providers to coordinate their care under a final

More information

Finalized Changes to the Medicare Shared Savings Program

Finalized Changes to the Medicare Shared Savings Program Finalized Changes to the Medicare Shared Savings Program Background: On June 4, 2015, the Centers for Medicare and Medicaid (CMS) issued a final rule that updates implementing regulations for the Medicare

More information

CMS Gainsharing Demonstration Projects. Mark Wynn, Director Division of Payment Policy Demonstrations, CMS

CMS Gainsharing Demonstration Projects. Mark Wynn, Director Division of Payment Policy Demonstrations, CMS CMS Gainsharing Demonstration Projects Mark Wynn, Director Division of Payment Policy Demonstrations, CMS Overview of Presentation Medicare demonstrations Gainsharing background Description of current

More information

Herb Kuhn August 29, 2007 Page 1 of 7. August 29, 2007

Herb Kuhn August 29, 2007 Page 1 of 7. August 29, 2007 Page 1 of 7 Herb Kuhn Acting Deputy Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: CMS-1385-P, Medicare

More information

May 26, 2011. Section 3022 of the Affordable Care Act. Dear Administrator Berwick:

May 26, 2011. Section 3022 of the Affordable Care Act. Dear Administrator Berwick: Donald M. Berwick, MD, MPP Administrator Attention: CMS-1345-P Mail Stop C4-26-05 7500 Security Boulevard Baltimore, MD 21244-1850 Re: Section 3022 of the Affordable Care Act Dear Administrator Berwick:

More information

The Stark Law Opportunities to Address Barriers to Clinical Integration January 29, 2016

The Stark Law Opportunities to Address Barriers to Clinical Integration January 29, 2016 The Stark Law Opportunities to Address Barriers to Clinical Integration There are several rules governing compensation relationships between hospitals, physicians and other caregivers, including the Anti-kickback

More information

Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options

Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options Legal Waivers under the Medicare Shared Savings Program: An Overview of the Options Robert G. Homchick Davis Wright Tremaine LLP Arthur N. Lerner Crowell & Moring LLP Shared Savings Program: ACOs Medicare

More information

Quality Accountable Care Population Health: The Journey Continues

Quality Accountable Care Population Health: The Journey Continues Quality Accountable Care Population Health: The Journey Continues Health Insights April 10, 2014 Doug Hastings 2001 Institute of Medicine 2 An Agenda For Crossing The Chasm Between the health care we have

More information

Accountable Care Organizations: The Final Rule

Accountable Care Organizations: The Final Rule Accountable Care Organizations: The Final Rule October 27, 2011 2011 Akin Gump Strauss Hauer & Feld LLP 10.27.11 101799002 v4 Overview Background Final Rule Highlights Structure and Formation of ACOs Quality

More information

Health Law Bulletin. provided by: ACOs AND SHARED SAVINGS IN A NUTSHELL Applications to Participate Available Now

Health Law Bulletin. provided by: ACOs AND SHARED SAVINGS IN A NUTSHELL Applications to Participate Available Now Health Law Bulletin provided by: ACOs AND SHARED SAVINGS IN A NUTSHELL Applications to Participate Available Now Earlier this month, the Center for Medicare and Medicaid Services (CMS) published the final

More information

Responses to Questions on Protection of Medicare Beneficiaries

Responses to Questions on Protection of Medicare Beneficiaries www.alz.org Public Policy Office 202 393 7737 p 1212 New York Avenue, NW 866 865 0270 f Suite 800 Washington, DC 20005-6105 The Honorable Max Baucus Chairman Senate Finance Committee The Honorable Orrin

More information

RE: File Code CMS-1345-NC2 Medicare Program Waiver Designs in Connection with the Medicare Shared Savings Program and Innovation Center

RE: File Code CMS-1345-NC2 Medicare Program Waiver Designs in Connection with the Medicare Shared Savings Program and Innovation Center Donald Berwick, M.D., M.P.P. Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-1345-NC2 Room 445-G Hubert H. Humphrey Building 200 Independence Ave. S.W.

More information

Changes for Calendar Year 2015 Physician Quality Programs and Other Programs in the Medicare Physician Fee Schedule

Changes for Calendar Year 2015 Physician Quality Programs and Other Programs in the Medicare Physician Fee Schedule DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services Room 352-G 200 Independence Avenue, SW Washington, DC 20201 FACT SHEET FOR IMMEDIATE RELEASE October 31, 2014 Contact: CMS

More information

Accelerating Innovation in Health Care Payment and Delivery: The CMS Innovation Center

Accelerating Innovation in Health Care Payment and Delivery: The CMS Innovation Center Accelerating Innovation in Health Care Payment and Delivery: The CMS Innovation Center William J. Kassler, MD, MPH Chief Medical Officer, New England Region Center for Medicare & Medicaid Innovation We

More information

Medicare Shared Savings Program

Medicare Shared Savings Program Medicare Shared Savings Program Shared Savings Program http://www.cms.gov/savingsprogram/ Centers for Medicare & Medicaid Services February 2012 Medicare Shared Savings Program (Shared Savings Program)

More information

HEALTH CARE LAW. Accountable Care Organizations

HEALTH CARE LAW. Accountable Care Organizations HEALTH CARE LAW September 10, 2010 Presented by University of Mississippi Center for Continuing Legal Education Topic: Accountable Care Organizations By Jonell Beeler Baker, Donelson, Bearman, Caldwell

More information

Medicare Shared Savings Program Final Rule

Medicare Shared Savings Program Final Rule Healthcare Committee Medicare Shared Savings Program Final Rule On June 9, 2015, the Centers for Medicare & Medicaid Services ( CMS ) published a final rule that, according to the agency, will update and

More information

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program

Amy K. Fehn. I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program IMPLEMENTING COMPLIANCE PROGRAMS FOR ACCOUNTABLE CARE ORGANIZATIONS Amy K. Fehn I. Overview of Accountable Care Organizations and the Medicare Shared Savings Program The Medicare Shared Savings Program

More information

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs)

Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) Fraud and Abuse Considerations for Accountable Care Organizations (ACOs) By: Chris Rossman, Foley & Lardner LLP, Detroit, Michigan 1. The Centers for Medicare and Medicaid Services ( CMS ) and the Office

More information

Accountable Care Organizations and Provider Integration Under Health Care Reform. Sarah Swank 202.326.5003 seswank@ober.com

Accountable Care Organizations and Provider Integration Under Health Care Reform. Sarah Swank 202.326.5003 seswank@ober.com Accountable Care Organizations and Provider Integration Under Health Care Reform Sarah Swank 202.326.5003 seswank@ober.com February 26, 2014 Overview Affordable Care Act and ACOs Trends in Integration

More information

AHLA. Q. Medicaid ACOs: Coming to a Neighborhood Near You. Clifford E. Barnes Epstein Becker & Green PC Washington, DC

AHLA. Q. Medicaid ACOs: Coming to a Neighborhood Near You. Clifford E. Barnes Epstein Becker & Green PC Washington, DC AHLA Q. Medicaid ACOs: Coming to a Neighborhood Near You Clifford E. Barnes Epstein Becker & Green PC Washington, DC Jennifer E. Gladieux Senior Health Policy Analyst Health Policy Source, Inc. Alexandria,

More information

The Accountable Care Organization

The Accountable Care Organization The Accountable Care Organization Kim Harvey Looney kim.looney@ 615-850-8722 3968555 1 ACOs: Will I Know One When I See One? Relatively New Concept Derived from Various Demonstration Programs No Set Structure

More information

Accountable Care Organization Workgroup Glossary

Accountable Care Organization Workgroup Glossary Accountable Care Organization Workgroup Glossary Accountable care organization (ACO) a group of coordinated health care providers that care for all or some of the health care needs of a defined population.

More information

Jan. 4, Dear Acting Administrator Slavitt:

Jan. 4, Dear Acting Administrator Slavitt: Providence Health & Services Valley Office Park 1801 Lind Avenue S.W., #9016 Renton, WA 98057 www.providence.org Jan. 4, 2016 Andrew M. Slavitt Acting Administrator Centers for Medicare and Medicaid Services

More information

Post-Acute Care and Long-Term Care: A Complex Relationship

Post-Acute Care and Long-Term Care: A Complex Relationship Post-Acute Care and Long-Term Care: A Complex Relationship PRESENTED TO: 2011 Long-Term Care Interest Group Policy Seminar PRESENTED BY: Allen Dobson, Ph.D. PREPARED BY: Allen Dobson, Ph.D., Joan E. DaVanzo,

More information

Healthcare Reform Update Conference Call VI

Healthcare Reform Update Conference Call VI Healthcare Reform Update Conference Call VI Sponsored by the Healthcare Reform Educational Task Force October 9, 2009 2:00-2:45 2:45 pm Eastern Healthcare Delivery System Reform Provisions in America s

More information

VIEW FROM WASHINGTON. Judi Lund Person, MPH Vice President, Compliance and Regulatory Leadership, NHPCO

VIEW FROM WASHINGTON. Judi Lund Person, MPH Vice President, Compliance and Regulatory Leadership, NHPCO 1 VIEW FROM WASHINGTON Judi Lund Person, MPH Vice President, Compliance and Regulatory Leadership, NHPCO Today we will discuss 2 Sequestration what s the latest New research on hospice cost savings Basic

More information

May 8, 2013. The Honorable Fred Upton Chairman House Committee on Energy and Commerce United States House of Representatives Washington, DC 20151

May 8, 2013. The Honorable Fred Upton Chairman House Committee on Energy and Commerce United States House of Representatives Washington, DC 20151 May 8, 2013 The Honorable Dave Camp Chairman House Committee on Ways and Means United States House of Representatives Washington D.C. 20515 The Honorable Fred Upton Chairman House Committee on Energy and

More information

Strengthening Medicare: Better Health, Better Care, Lower Costs Efforts Will Save Nearly $120 Billion for Medicare Over Five Years.

Strengthening Medicare: Better Health, Better Care, Lower Costs Efforts Will Save Nearly $120 Billion for Medicare Over Five Years. Strengthening Medicare: Better Health, Better Care, Lower Costs Efforts Will Save Nearly $120 Billion for Medicare Over Five Years Introduction The Centers for Medicare and Medicaid Services (CMS) and

More information

Accountable Care Fundamentals for Medical Practice Executives

Accountable Care Fundamentals for Medical Practice Executives Accountable Care Fundamentals for Medical Practice Executives Nathan Anspach, FACMPE Senior Vice President and Chief Executive Officer John C. Lincoln Accountable Care Organization and John C. Lincoln

More information

Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones

Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones Statement of the Association of American Medical Colleges on Legal Issues Related to Accountable Care Organizations and Healthcare Innovation Zones Public Workshop hosted by the FTC, CMS, HHS OIG October

More information

April 17, 2014. Re: Evolution of ACO initiatives at CMS. Dear Dr. Conway:

April 17, 2014. Re: Evolution of ACO initiatives at CMS. Dear Dr. Conway: Patrick Conway, M.D. Acting Director of the Innovation Center Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W. Room 445-G Washington, DC 20201 Re: Evolution

More information

ACOs. ACO Definition. ACO Governance. Stuart B Black MD, FAAN Chief of Neurology Co-Director: Neurosciences Baylor University Medical Center at Dallas

ACOs. ACO Definition. ACO Governance. Stuart B Black MD, FAAN Chief of Neurology Co-Director: Neurosciences Baylor University Medical Center at Dallas Stuart B Black MD, FAAN Chief of Neurology Co-Director: Neurosciences Baylor University Medical Center at Dallas ACOs ACO Definition CMS definition of ACO Accountable Care Organizations (ACOs) are groups

More information

Medicare Shared Savings Program: Accountable Care Organizations. Centers for Medicare and Medicaid Services Final Rule Provisions

Medicare Shared Savings Program: Accountable Care Organizations. Centers for Medicare and Medicaid Services Final Rule Provisions Medicare Shared Savings Program: Accountable Care Organizations Centers for Medicare and Medicaid Services Final Rule Provisions The Centers for Medicare and Medicaid Services (CMS) published a final rule

More information

ACOs: Fraud & Abuse Waivers and Analysis

ACOs: Fraud & Abuse Waivers and Analysis ACOs: Fraud & Abuse Waivers and Analysis Robert G. Homchick and Sarah Fallows Davis Wright Tremaine, LLP I. Introduction The Patient Protection and Affordable Care Act of 2010 (ACA) fosters the development

More information

Adding Value to. Provider Compensation. June 13, 2016. Healthcare Strategy Group OHA Presentation 2016. Adding Value to. Physician Compensation

Adding Value to. Provider Compensation. June 13, 2016. Healthcare Strategy Group OHA Presentation 2016. Adding Value to. Physician Compensation Provider Compensation June 13, 2016 1 Who are We? About (HSG) Hospital-physician integration specialists since 1999 Strategic, best practice approach to employed physician networks and independent physician

More information

Cornerstone Health Care, P.A.

Cornerstone Health Care, P.A. Cornerstone Health Care, P.A. Medicare Shared Savings Program ACO Compliance NAACOS July 2013 Agenda 1. Background 2. Compliance Requirements & Purpose 3. Cornerstone s experience 4. Q&A 2 Cornerstone

More information

Post-Acute/Long- Term Care Planning for Accountable Care Organizations

Post-Acute/Long- Term Care Planning for Accountable Care Organizations White Paper Post-Acute/Long- Term Care Planning for Accountable Care Organizations SCORE A Model for Using Incremental Strategic Positioning as a Planning Tool for Participation in Future Healthcare Integrated

More information

Submitted via the Federal erulemaking Portal: http://www.regulations.gov

Submitted via the Federal erulemaking Portal: http://www.regulations.gov Page 1 June 10, 2013 Submitted via the Federal erulemaking Portal: http://www.regulations.gov The Honorable Marilyn Tavenner Administrator Centers for Medicare & Medicaid Services U.S. Department of Health

More information

E. Christopher Ellison, MD, F.A.C.S Senior Associate Vice President for Health Sciences

E. Christopher Ellison, MD, F.A.C.S Senior Associate Vice President for Health Sciences Accountable Care Organizations and You E. Christopher Ellison, MD, F.A.C.S Senior Associate Vice President for Health Sciences CEO, OSU Faculty Group Practice Chair, Department of Surgery Ohio State University

More information

September 3, Submitted electronically

September 3, Submitted electronically September 3, 2015 Andrew M. Slavitt Acting Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: CMS-1622-P Room 445-G Hubert H. Humphrey Building

More information

Post-acute care providers: Shortcomings in Medicare s fee-for-service highlight the need for broad reforms

Post-acute care providers: Shortcomings in Medicare s fee-for-service highlight the need for broad reforms C h a p t e r7 Post-acute care providers: Shortcomings in Medicare s fee-for-service highlight the need for broad reforms C H A P T E R 7 Post-acute care providers: Shortcomings in Medicare s fee-for-service

More information

How to Prepare for CMS Bundled Payments

How to Prepare for CMS Bundled Payments How to Prepare for CMS Bundled Payments Mandatory bundled payments for joint replacement will serve as many hospitals first pilot program for value-based reimbursement in 2016. Combined with the five-star

More information

CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS

CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS CLINICALLY INTEGRATED NETWORKS: BUSINESS AND LEGAL CONSIDERATIONS Claire Turcotte, Esquire, Bricker & Eckler LLP Jim Yanci, MS MT (ASCP), Dixon Hughes Goodman Agenda BUSINESS CONSIDERATIONS How Fast are

More information

ACO Definition Cont d 11/15/15. What is an Accountable Care Organization (ACO) Michelle S. McOmber, MBA, CAE CEO, Utah Medical Association

ACO Definition Cont d 11/15/15. What is an Accountable Care Organization (ACO) Michelle S. McOmber, MBA, CAE CEO, Utah Medical Association Michelle S. McOmber, MBA, CAE CEO, Utah Medical Association What is an Accountable Care Organization (ACO) Accountable Care Organizations were created through the Affordable Care Act. Definition: An ACO

More information

PL 111-148 and Amendments: Impact on Post-Acute Care for Health Care Systems

PL 111-148 and Amendments: Impact on Post-Acute Care for Health Care Systems PL 111-148 and Amendments: Impact on Post-Acute Care for Health Care Systems By Kathleen M. Griffin, PhD. There are three key provisions of the law that will have direct impact on post-acute care needs

More information

An Update on Payment Reform Activities at CMS and How Data Analytics and Rapid-Cycle Evaluation Support Transformation

An Update on Payment Reform Activities at CMS and How Data Analytics and Rapid-Cycle Evaluation Support Transformation An Update on Payment Reform Activities at CMS and How Data Analytics and Rapid-Cycle Evaluation Support Transformation William Shrank, MD MSHS Division of Pharmacoepidemiology and Pharmacoeconomics Harvard

More information

Participating Accountable Care Organizations (ACOs) that meet quality performance standards will be eligible to receive payments for shared savings.

Participating Accountable Care Organizations (ACOs) that meet quality performance standards will be eligible to receive payments for shared savings. Background Sec. 3022 of the Patient Protection and Affordable Care Act (PPACA) requires the Secretary to establish the Medicare Shared Savings Program by Jan. 1, 2012 Program goals: Promote accountability

More information

Our Changing & Challenging Health Care Landscape: A Brief Overview

Our Changing & Challenging Health Care Landscape: A Brief Overview Welcome! Our Changing & Challenging Health Care Landscape: A Brief Overview Sheryl Slonim, DNP, RN-BC, NEA-BC Executive Vice President, Patient Care Svcs/CNO Welcome! Our Changing & Challenging Health

More information

Advance Care Planning Services

Advance Care Planning Services September 8, 2015 Andrew Slavitt Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G Hubert H. Humphrey Building 200 Independence, Ave., S.W.

More information

Nuts and Bolts Accountable Care Organizations: A New Care Delivery Model for New Expectations

Nuts and Bolts Accountable Care Organizations: A New Care Delivery Model for New Expectations Nuts and Bolts Accountable Care Organizations: A New Care Delivery Model for New Expectations Presented to The American College of Cardiology October 27, 2012 1 Franciscan Alliance Overview Franciscan

More information

March 28, 2016. Dear Acting Administrator Slavitt:

March 28, 2016. Dear Acting Administrator Slavitt: March 28, 2016 Andrew Slavitt, Acting Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attention: CMS 1644-P P.O. Box 8013 Baltimore, MD 21244 8013 Re: Medicare

More information

HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS

HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS HEALTH REFORM LAW: ACCOUNTABLE CARE ORGANIZATIONS PRESENTED AT THE NASABA 2011 CONVENTION BY: PURVI B. MANIAR Context and Background Patient Protection and Affordable Care Act of 2010 ( PPACA ) (Section

More information

1900 K St. NW Washington, DC 20006 c/o McKenna Long

1900 K St. NW Washington, DC 20006 c/o McKenna Long 1900 K St. NW Washington, DC 20006 c/o McKenna Long Centers for Medicare & Medicaid Services U. S. Department of Health and Human Services Attention CMS 1345 P P.O. Box 8013, Baltimore, MD 21244 8013 Re:

More information

Who, What, When and How of ACOs. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program

Who, What, When and How of ACOs. Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program Who, What, When and How of ACOs Summary of proposed rule provisions for Accountable Care Organizations under the Medicare Shared Savings Program April 5, 2011 On March 31, 2011, the Centers for Medicare

More information

MACRA MIPS and CME. Working Group 3/17/16

MACRA MIPS and CME. Working Group 3/17/16 MACRA MIPS and CME Working Group 3/17/16 MACRA, MIPS and CME Enacted in April 2015 Eliminates SGR; Requires EHR interoperability by 2018 Creates Two New Payment Paths for Medicare Eligible Provider Reimbursement

More information

5/3/2016. Value-Based Purchasing in Minnesota Medicaid AGENDA

5/3/2016. Value-Based Purchasing in Minnesota Medicaid AGENDA Value-Based Purchasing in Minnesota Medicaid Gretchen Ulbee Manager, Special Needs Purchasing, Health Care Administration Minnesota Department of Human Services May 11, 2016 AGENDA What is Value-Based

More information

Chapter Seven Value-based Purchasing

Chapter Seven Value-based Purchasing Chapter Seven Value-based Purchasing Value-based purchasing (VBP) is a pay-for-performance program that affects a significant and growing percentage of Medicare reimbursement for medical providers. It

More information

HEALTHCARE REFORM OCTOBER 2012

HEALTHCARE REFORM OCTOBER 2012 HEALTHCARE REFORM Tracking ACO Growth Nationally OCTOBER 2012 The enclosed slides are intended to provide you with a snapshot of how private sector accountable care organizations (ACOs) have formed since

More information

Accountable Care Organizations Understanding What They Are and How to Structure Them

Accountable Care Organizations Understanding What They Are and How to Structure Them Accountable Care Organizations Understanding What They Are and How to Structure Them Maria T. Currier HOLLAND & KNIGHT LLP Miami Chamber of Commerce Healthcare Subcommittee December 7, 2010 Copyright 2010

More information