How Will the ACO Regulations Affect You?

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "How Will the ACO Regulations Affect You?"

Transcription

1 How Will the ACO Regulations Affect You? Wednesday, June 1, 2011 Presented by: Michele Madison Partner, Healthcare & Healthcare IT Practices Ward Bondurant Partner, Healthcare, Insurance & Corporate Practices Joe Holahan Of Counsel, Insurance & Corporate Practices

2 What is an ACO? Accountable care organization (ACO) Means a legal entity that is recognized and authorized under applicable State law; Identified by a Taxpayer Identification Number (TIN); Comprised of an eligible group of ACO participants that work together to manage and coordinate care for Medicare FFS beneficiaries; and Have established a mechanism for shared governance that provides all ACO participants with an appropriate proportionate control over the ACO's decision making process. 2

3 Statutory Basis Shared Savings Program is part of the Patient Protection and Affordable Care Act to be codified at 42 USC It is not a demonstration program. It is part of the Statute and the effective date is January 1,

4 Impact on Healthcare Coordinates the delivery of care between providers. Encourages investment in infrastructure (Healthcare IT). Encourages the redesign of care processes to focus upon quality and efficiencies. 4

5 Basic Requirements 1. Accountable for the quality, cost, and the overall care of the Medicare fee-for-service (FFS) beneficiaries assigned to it. 2. Enter into an agreement with the Secretary to participate in the program for not less than a 3-year period. 3. Formal legal structure that would allow the organization to receive and distribute payments for shared savings to participating providers of services and suppliers. 4. Include primary care professionals that are sufficient for the number of Medicare FFS beneficiaries assigned to the ACO. (At least 5000 beneficiaries). 5

6 Basic Requirements 5. Provide the Secretary with such information regarding ACO professionals participating in the ACO as the Secretary determines necessary to support the assignment of Medicare fee-for-service beneficiaries to an ACO, the implementation of quality and other reporting requirements, and the determination of payments for shared savings. 6. Maintain leadership and management structure that includes clinical and administrative systems. 7. Define processes to promote evidence-based medicine and patient engagement. 6

7 Basic Requirements 8. Report on quality and cost measures, and coordinate care, such as through the use of telehealth, remote patient monitoring, and other such enabling technologies. 9. Demonstrate to the Secretary that the ACO meets patientcenteredness criteria specified by the Secretary, such as the use of patient and caregiver assessments or the use of individualized care plans. 7

8 Eligible Entities ACO professionals in group practice arrangements. Networks of individual practices of ACO professionals. Partnerships or joint venture arrangements between hospitals and ACO professionals. Hospitals employing ACO professionals. Such other groups of providers of services and suppliers as the Secretary determines. 8

9 Eligible Entities Limits and excludes some key areas of the healthcare delivery system: FQHC RHC CAH Secretary has the discretion to include some of these providers. 9

10 Legal Entity/Governance Recognized under State Law as Legal Entity with a TIN. Governing Body must have 75% representation from ACO members. Financial and clinical Integration. A leadership and management structure that includes clinical and administrative systems. 10

11 Assignment of Beneficiaries Assigned based on plurality of primary care services with a PCP in an ACO. Based on allowed charges, not a simple count of services. Assigned retrospectively for calculating savings. CMS will provide list of beneficiaries. PCPs can only participate in 1 ACO. 11

12 Shared Savings Meet all minimum quality performance standards. Achieve spending less than benchmark. Savings greater than minimum savings requirement. 12

13 Shared Savings Two types: One-sided Savings only for 2 years. Capped at 7.5% of benchmark. Share 50% of savings over minimum up to cap. Weighted by quality score. Year 3 move to upside/downside model. Two-sided Savings or losses. Savings capped at 10% of benchmark. Share 60% of savings over minimum up to cap. Weighted by quality score. Losses capped at 5% Year 1, 7.5% Year 2, 10% Year 3. 13

14 Eligibility: Required Processes The ACO application will require the applicant to describe its plans for: Processes to promote evidence-based medicine the application of the best available evidence gained from the scientific method to clinical decision-making. The establishment and implementation of evidence-based guidelines, based on the best available evidence concerning the effectiveness of medical treatments, at the organizational or institutional level; plus Regular assessment and updating of guidelines to promote continuous improvement in the quality of care in light of new evidence concerning the effectiveness of medical treatments. 14

15 Eligibility: Required Processes Processes to promote patient engagement the active participation of patients and their families in the process of making medical decisions. The opportunity for patients and families to assess prospective treatment approaches in the light of their own values and convictions. Also includes methods for promoting "health literacy" in patients and their families, including basic knowledge about maintaining good health, avoiding preventable medical conditions, managing existing conditions, and knowledge about how the care system works. 15

16 Eligibility: Required Processes Processes to report on quality and cost measures Such as developing a population health data management capability, or implementing practice and physician level data capabilities with point-of-service (POS) reminder systems to drive improvement in quality and cost outcomes. ACOs expected to be able to monitor both costs and quality internally and make appropriate modifications based upon their collection of such information. 16

17 Eligibility: Required Processes Processes to promote coordination of care Strategies to promote, improve, and assess integration and consistency of care across primary care physicians, specialists, and acute and post-acute providers and suppliers. Includes methods to manage care throughout an episode of care and during its transitions (i.e. discharge from a hospital or transfer of care from a primary care physician to a specialist). May include such strategies as predictive modeling to anticipate likely care needs; case managers in primary care offices; specific transition of care programs that include guidance and instructions for patients, their families, and their caregivers; remote monitoring; telehealth; and the use of health information technology to transfer patient care information in transitions. 17

18 Eligibility Requirements: Patient Centeredness Criteria An ACO must be able to show that it meets specified patientcenteredness criteria. care that incorporates the values (to the extent the informed, individual patient desires it) of transparency, individualization, recognition, respect, dignity, and choice in all matters, without exception, related to one's person, circumstances, and relationships in health care. Patient-centered care should extend not only to the patient but to the family and caregivers of the patient. 18

19 8 required criteria Eligibility Requirements: Patient Centeredness Criteria 1. Patient experience of care survey. 2. Patient involvement in governance of the ACO. 3. Evaluation of population health needs and consideration of diversity in patient population. 4. Systems to identify high-risk individuals and processes to develop individualized care plans for targeted patient populations, including integration of community resources. 5. Mechanisms for the coordination of care. 19

20 Eligibility Requirements: Patient Centeredness Criteria 8 required criteria (continued) 6. Processes for communicating clinical knowledge/evidence-based medicine to patients. 7. Patient access and communication and a process in place for patients to access their medical record. 8. Internal processes for measuring clinical or service performance by physicians across the practices, using these results to improve care and service. 20

21 Eligibility Requirements: Program Integrity Requirements ACO must include program integrity criteria to protect the Shared Savings Program (and other parts of Medicare or other Federal health care) from fraud and abuse. ACO must meet each of the following program integrity criteria: A compliance plan, including: A designated compliance official (other than legal counsel). Mechanisms for identifying and addressing compliance problems. A method for employees/contractors to report problems. Compliance training. A requirement to report suspected violations. 21

22 Eligibility Requirements: Program Integrity Requirements Policies and procedures designed to monitor compliance with program requirements, including requirements for certification of information by an authorized representative of the ACO. Conflicts of interest policy that applies to members of the ACO s governing board. Screening of ACO applicants and exclusion of applicants that have had program integrity problems. Prohibition on certain required referrals and cost shifting relating to beneficiaries not assigned to the ACO. 22

23 Quality and Other Reporting Requirements Three stated goals for improvement of the health care of Medicare beneficiaries and, by extension, of all Americans. 1. Better care for individuals; 2. Better health for populations; and 3. Lower growth in expenditures. Better health care for individuals defined as health care that is safe, effective, patient-centered, timely, efficient, and equitable. The Quality Performance Standards sections of the proposed rule relate to the first two goals. 23

24 Quality Performance Standards To prevent ACO participants from achieving savings by withholding necessary services, the ACO must meet minimum performance standards based on specified quality measures in order to be eligible for any shared savings payment for a given year. For Year 1, an ACO is just required to report on all of the measures, and will receive the highest percentage of shared savings available to that ACO. For each subsequent year, the ACO s actual performance score on the quality measures (expressed as a percentage of total points available) will determine the percentage of savings the ACO will receive. If those scores fall below a certain level, the ACO will not be eligible for any shared savings payment. Quality measures for these years will be published in advance. 24

25 Quality Performance Standards The Proposed Regulations specify 65 measures (see Table 1 in the Regs) based on the aims of improved care and improved health. Each measure has NQF endorsement or is currently used in other CMS quality programs. Improved Care measures are organized in three domains: Patient/caregiver experience (7 measures, all based on survey results); Care coordination (16 measures, including percentage of ACO participants that meet HITECH meaningful use requirements); Patient safety (2 measures). Improved Health measures are organized in two domains: Preventive health (9 measures) and At-risk populations/frail elderly (29 measures, including diabetes (10 measures); heart failure (7 measures); coronary artery disease (5 measures); hypertension (2 measures); COPD (3 measures); and frail elderly (2 measures)). 25

26 Quality Performance Standards [Excerpt from Table 1 of the Proposed Regulations] Domain Measure Title & Description CMS Program, NQF Measure Number, Measure Steward Method of Data Submission Measure Type AIM: Better Care for Individuals 1 Patient/Care Giver Experience Clinician/Group CAHPS: Getting Timely Care, Appointments, and Information NQF #5 Survey Patient Experience of Care 2 Patient/Care Giver Experience Clinician/Group CAHPS: How Well Your Doctors Communicate NQF #5 Survey Patient Experience of Care 3 Patient/Care Giver Experience Clinician/Group CAHPS: Helpful, Courteous, Respectful Office Staff NQF #5 Survey Patient Experience of Care 26

27 Quality Measures Data Collection Data collection and submission methods: Most performance measures can be derived from CMS data. Many of the measures are based on data similar to that collected for other purposes, such as the Physician Quality Reporting System, EHR Incentive Program, etc. For quality data not captured in claims processing systems, CMS will make available a CMS-specified data collection tool (see measures designated for Group Practice Reporting Option (GPRO) Data Collection Tool in Table 1). Some measures specify the use of patient survey instruments. For future program years, certified EHR technology may serve as additional measures reporting mechanism. 27

28 Quality Performance Scoring Two options for measuring performance standards: Option 1 Performance Scoring Step One: Score each Measure (see Table 3) Step Two: Combine Measure scores within each Domain Step Three: Calculate percentage per Domain (see Table 4) Step Four: Combine Domain percentages into one percentage Step Five: Apply percentage to applicable total potential shared savings (50% for one-sided and 60% for two-sided) Failure to reach the minimum level for a Domain would preclude shared savings and could result in termination. 28

29 Quality Performance Scoring Table 3: Sliding Scale Measure Scoring Approach ACO Performance Level 90+ percentile FFS/MA Rate or 90+ percent 80+ percentile FFS/MA Rate or 80+ percent 70+ percentile FFS/MA Rate or 70+ percent 60+ percentile FFS/MA Rate or 60+ percent 50+ percentile FFS/MA Rate or 50+ percent 40+ percentile FFS/MA Rate or 40+ percent 30+ percentile FFS/MA Rate or 30+ percent <30 percentile FFS/MA Rate or <30 percent Quality Points 2 points 1.85 points 1.7 points 1.55 points 1.4 points 1.25 points 1.10 point No points 29

30 Quality Performance Scoring Table 4: Total Points for Each Domain within the Quality Performance Standard Domain Category Table 1 Measures (Total) One-Sided Model Total Potential Points Per Domain Two-Sided Model Total Potential Points Per Domain 1.Patient/Caregiver Experience 1-7 (7 measures) Care Coordination 8-23 (16 measures) Patient Safety (2 measures) Preventive Health (9 measures ) At-Risk Population/Frail Elderly Health Diabetes Heart Failure Coronary Artery Disease Hypertension Chronic Obstructive Pulmonary Disorder Frail Elderly (31 measures) Total Quality Points Available Total Potential Shared Savings 50% 60% 30

31 Quality Threshold Option Option 2 Quality Threshold Alternative calculation offered for comment. All-or-none savings sharing based on attaining minimum quality threshold. Minimum quality threshold would be 50% for each Domain (see Table 3). Provides some certainty and less risk, but reduces incentive to continue to improve quality above threshold. 31

32 Public Reporting Information regarding the ACO that should be publicly reported: Name and location Primary contact Organizational information including: ACO participants; Identification of ACO participants in joint ventures between ACO professionals and hospitals; Identification of the ACO participant representatives on its governing body; and Associated committees and committee leadership. Shared savings information including: Shared savings performance payment received by ACOs or shared losses payable to CMS; and Total proportion of shared savings invested in infrastructure, redesigned care processes and other resources required to support the three-part aim goals, including the proportion distributed among ACO participants. Quality performance standard scores 32

33 Proposed Rule Leaves Room For State Regulation CMS suggests that ACOs do not assume insurance risk. Medicare retains insurance risk and responsibility for paying claims for services rendered to Medicare beneficiaries. [T]he agreement to share risk against the benchmark would be solely between the Medicare program and the ACO. Nothing in the proposed rule intended to cause states to bear costs resulting from Shared Savings Program. But leaves the door open for state regulation. Each state has its own insurance and risk oversight programs. [S]ome states may regulate risk bearing entities, such as the ACOs participating in the two-sided model. We do not believe that there is anything in this proposed rule that either explicitly or implicitly pre-empts any State law. 33

34 Will States Regulate ACOs? ACOs do not fit definitions commonly found under state laws governing risk-bearing entities, such as HMOs and health service plans. No prepayment for health care services. No contractual relationship between beneficiaries and ACO. No direct restrictions on beneficiaries. Nevertheless, ACOs have features that could prompt state regulation. ACO bears financial risk. Participating providers are subject to downstream risk. Shared Savings could raise same concerns as other attempts at managing care with an eye towards reducing cost. 34

35 Important to Evaluate ACO on State-by-State Basis Evaluate laws and regulations relating to: Licensed risk-bearing entities Third-party administrators Utilization review agents Managed care generally Keep a close eye on NAIC discussions and regulatory guidance. 35

36 Captive Insurance for ACOs Captive can provide mechanism to ensure repayment of losses to Medicare. Participating providers may see value in captive program to cover professional liability risks. Professional liability exposure may increase for providers participating in ACO. Consistent approach to claims investigation and defense. Take advantage of ACO data collection and governance. Shared savings from improvements in patient safety. Captive can be used to cover liability risks of ACO, its governing body and management. 36

37 Antitrust Policy Statement ACO must determine its expected market share in each ACO participant s primary service area (referred to as PSA Shares ) for specific health care services, based on Medicare claims data. If (a) the combined PSA Shares for two or more participants does not exceed 30 percent, and (b) none of the ACO s hospitals or ASCs are exclusive to that ACO, the ACO will qualify for the antitrust safety zone. The ACO will not be subject to antitrust challenge absent extraordinary circumstances. Special rules apply if ACO participants include a dominant provider or a certain number of rural hospitals or physicians. If the combined PSA Shares for any two or more participants in the ACO exceeds 50 percent, the ACO must apply for expedited (90 day) antitrust clearance prior to applying to CMS. Without such clearance, the ACO is not eligible for the Program. If an ACO has a PSA Share between 31 and 50 percent, that ACO has the option of requesting clearance from the antitrust agencies. An ACO that voluntarily seeks antitrust clearance runs the risk of being barred from the Program if the antitrust agencies deny the request. Once an ACO receives antitrust clearance from the antitrust agencies and is approved for the Program, the ACO participants also may negotiate jointly with private insurance companies (i.e., enter into single signature contracts, as opposed to utilization of the messenger model). 37

38 AMGA Letter (May 11 th ) American Medical Group Association concerns over the direction of the Proposed Rule: Overly prescriptive, operationally burdensome, and the incentives are too difficult to achieve to make this voluntary program attractive. In a survey of AMGA members, 93 percent said they would not enroll as an ACO under the current regulatory framework. Members concerns focused on issues such as the risk sharing requirement, static risk adjustment, retrospective attribution, quality measurement requirements, the Minimum Savings Rate requirements and others. Without substantial changes in the Final Rule, fear that very few providers will enroll as ACOs and that CMS and the provider community will miss the best opportunity to inject value and accountability into the delivery system. 38

39 PGP Demonstration Group Letter (May 12 th ) Reservations about the economics and the complexity of the proposed regulations, including: Downside risk during the initial 3-year term; downside risk is compounded by significant investment cost on the part of the ACO. Savings are measured net of 2% threshold for the one-sided risk model; the Minimum Savings Rate (MSR) is set at high levels for ACOs with lower enrollment. Limits placed on accounting for beneficiary acuity level that is documented and appropriate will dilute true savings realized by the ACO, and is a disincentive for management of patients with complex care needs. A large number of quality measures, especially new quality metrics in several domains, that go into effect starting year one; on average, it costs about $30,000 just to program a single new quality metric; the regulations have more than 60 new ones, which equates to nearly $2,000,000 for each organization. Retrospective attribution places limits on the ACO s ability to bend the cost curve; it impedes optimal patient engagement, timely program planning and course correction, and compounds underlying issues of claims lag and financial settlement. Logistics associated with Medicare beneficiaries opt-out of the ACO program is not practical; this would lead to beneficiary and physician confusion on the terms of engagement. 39

40 Innovation Center Release (May 17 th ) Pioneer ACO Model: The Innovation Center is accepting applications for the Pioneer ACO Model which will provide a faster path for mature ACOs that have already begun coordinating care for patients. Estimated to save Medicare as much as $430 million over three years. Designed to work in coordination with private payers in order to achieve cost savings and improve quality across the ACO, improving health outcomes and reducing costs for employers and patients with private insurance. Advance Payment ACO Initiative: The Innovation Center is seeking public comments on whether it should offer an Advance Payment Initiative that would allow certain ACOs access to a portion of their shared savings up front, helping providers make the infrastructure and staff investments crucial to successful ACOs. Comments should be submitted by June 17th,

41 CMI Creation of Centers for Medicare and Medicaid Innovation (CMI). The CMI will be the major focal point for the identification of problem areas in health care delivery and identification and testing of new models to improve program performance. To design, implement and evaluate Medicare and Medicaid demonstrations and pilot programs to test the feasibility, cost effectiveness and quality outcomes of new health care delivery models. 41

42 CMI Cont d To promote research and demonstration transparency by disseminating findings to inform law makers and interested parties about health care delivery issues, new innovative concepts, and demonstrations and pilot programs. Evaluative findings to develop new objectives for basic research and new research demonstrations. Has the authority to extend and expand the operation of successful models. 42

43 Other Models Independence at Home Demonstration Program. Hospital Readmissions Reduction Program. Community-Based Care Transitions Program. Value Based Purchasing. 43

44 Payment Models Linking payment to quality. Enhanced quality reporting for physicians and hospitals. Be ready for HIPAA 5010 and ICD

45 Governmental Incentives Medicare and Medicaid EHR Programs PQRI Incentives E-prescribing Incentives 45

46 Thank You for Joining Us Today Please contact any of our presenters after the presentation if you have additional questions: Michele Madison Partner, Healthcare & Healthcare IT Practices / Ward Bondurant Partner, Healthcare, Insurance & Corporate Practices / Joe Holahan Of Counsel, Insurance & Corporate Practices / 46

47 Disclaimer The materials and information presented and contained within this document are provided by MMM as general information only, and do not, and are not intended to constitute legal advice. Any opinions expressed within this document are solely the opinion of the individual author(s) and may not reflect the opinions of MMM, individual attorneys, or personnel, or the opinions of MMM clients. The materials and information are for the sole use of their recipient and should not be distributed or repurposed without the approval of the individual author(s) and Morris, Manning & Martin LLP. This document is Copyright 2011 Morris, Manning & Martin, LLP. All Rights Reserved worldwide. 47

Medicare Final Accountable Care Organization (ACO) Regulations Effective January 1, 2012 Median Savings of $470 Million over 4 Years

Medicare Final Accountable Care Organization (ACO) Regulations Effective January 1, 2012 Median Savings of $470 Million over 4 Years October 20, 2011 CIT Healthcare, John M. Cousins, SVP Healthcare Intelligence john.cousins@cit.com Tel: 850-668-2907 Cell: 716-867-9965 Medicare Final Accountable Care Organization (ACO) Regulations Effective

More information

Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011

Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011 Accountable Care Organizations (ACO) Proposed Rule Summary March 31, 2011 On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) released the longawaited proposed rule on Accountable Care

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

Accountable Care Organizations: Notice of Proposed Rulemaking

Accountable Care Organizations: Notice of Proposed Rulemaking Accountable Care Organizations: Notice of Proposed Rulemaking Presentation by: Pam Silberman, JD, DrPH North Carolina Institute of Medicine April 15, 2011 1 Accountable Care Organizations (ACOs) An ACO

More information

CMS Releases Proposed Rule Governing Accountable Care Organizations

CMS Releases Proposed Rule Governing Accountable Care Organizations CMS Releases Proposed Rule Governing Accountable Care Organizations Health Care Organizations Face Complex Strategic Decisions Authors: Robert D. Belfort Paul M. Campbell Susan R. Ingargiola Stephanie

More information

Gold Coast Health IT Resource Center. Accountable Care Organization (ACO)

Gold Coast Health IT Resource Center. Accountable Care Organization (ACO) Gold Coast Health IT Resource Center Accountable Care Organization (ACO) August 27, 2013 Copyright 2013 Gold Coast HIT 1 Agenda Upcoming Webinars ACO s Copyright 2013 Gold Coast HIT 2 Upcoming Webinars

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

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

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

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

PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES

PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES PROPOSED MEDICARE SHARED SAVINGS (ACO) PROGRAM RULES The Centers for Medicare and Medicaid Services (CMS) and other affected agencies released their notice of proposed rulemaking/request for comment for

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

What is an ACO? What forms of organizations may become an ACO? IAMSS 30 th Annual Education Conference Pearls of Wisdom

What is an ACO? What forms of organizations may become an ACO? IAMSS 30 th Annual Education Conference Pearls of Wisdom IAMSS 30 th Annual Education Conference Pearls of Wisdom The Impact of Accountable Care Organizations (ACOs) and Health Care Reform on Credentialing, Privileging and Peer Review April 28-29, 2011 Michael

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

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

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

PROPOSED RULES FOR ACCOUNTABLE CARE ORGANIZATIONS PARTICIPATING IN THE MEDICARE SHARED SAVINGS PROGRAM: WHAT DO THEY SAY?

PROPOSED RULES FOR ACCOUNTABLE CARE ORGANIZATIONS PARTICIPATING IN THE MEDICARE SHARED SAVINGS PROGRAM: WHAT DO THEY SAY? PROPOSED RULES FOR ACCOUNTABLE CARE ORGANIZATIONS PARTICIPATING IN THE MEDICARE SHARED SAVINGS PROGRAM: WHAT DO THEY SAY? The Affordable Care Act authorizes the Centers for Medicare and Medicaid Services

More information

M E M O R A N D U M. CMS Proposed Rule & Related Agency Notices on Accountable Care Organizations

M E M O R A N D U M. CMS Proposed Rule & Related Agency Notices on Accountable Care Organizations 1501 M Street NW Seventh Floor Washington, DC 20005-1700 Tel: 202.466.6550 Fax: 202.785.1756 M E M O R A N D U M To: From: Clients and Friends Powers Pyles Sutter & Verville, PC Date: April 10, 2011 Re:

More information

Crosswalk: CMS Shared Savings Rules & NCQA ACO Accreditation Standards 12/1/2011

Crosswalk: CMS Shared Savings Rules & NCQA ACO Accreditation Standards 12/1/2011 Crosswalk: CMS Shared Savings Rules & NCQA ACO Accreditation Standards 12/1/2011 The table below details areas where NCQA s ACO Accreditation standards overlap with the CMS Final Rule CMS Pioneer ACO CMS

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

Medicare ACO Road Map

Medicare ACO Road Map PYALeadership Briefing Medicare ACO Road Map January, 2013 Medicare ACO Road Map The Centers for Medicare & Medicaid Services ( CMS ) has announced 106 new accountable care organizations ( ACOs ) have

More information

Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program

Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program M A Y 2 0 1 1 Guidance Released on Accountable Care Organizations Participating in the Medicare Shared Savings Program On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS), the Department

More information

Client Advisory. CMS Issues Final ACO Regulations EXECUTIVE SUMMARY. Health Care. Eligibility. November 10, 2011

Client Advisory. CMS Issues Final ACO Regulations EXECUTIVE SUMMARY. Health Care. Eligibility. November 10, 2011 Client Advisory Health Care November 10, 2011 CMS Issues Final ACO Regulations After receiving more than 1,300 public comments on its Proposed Rule for Accountable Care Organizations (ACOs) under the Medicare

More information

Accountable Care Organizations: Importance to Physicians in Value Based Payment June 19, 2014 12:00-1:00pm EST

Accountable Care Organizations: Importance to Physicians in Value Based Payment June 19, 2014 12:00-1:00pm EST Accountable Care Organizations: Importance to Physicians in Value Based Payment June 19, 2014 12:00-1:00pm EST Ahmed Haque, Director of Care Transformation Health IT U.S. Department of Health & Human Services

More information

Entities eligible for ACO participation

Entities eligible for ACO participation On Oct. 20, 2011, the Centers for Medicare & Medicaid Services (CMS) finalized new rules under the Medicare Shared Savings Program (MSSP) to help doctors, hospitals, and other health care providers better

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

OUR ACO QUALITY RESULTS 2012 AND 2013

OUR ACO QUALITY RESULTS 2012 AND 2013 OUR ACO QUALITY RESULTS 2012 AND 2013 2012-2013 Patient and Caregiver Experience Source 2012 2013 ACO - 1 CAHPS: Getting Timely Care, Appointments and Information Survey 81.98 84.47 ACO - 2 CAHPS: How

More information

Accountable Care Organizations: How Does the DME Join the Party?

Accountable Care Organizations: How Does the DME Join the Party? Accountable Care Organizations: How Does the DME Join the Party? Presented by: Jeffrey S. Baird, Esq. Chairman, Health Care Group, Brown & Fortunato, P.C. 2015 Brown & Fortunato, P.C. BACKGROUND 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

Overview and Legal Context

Overview and Legal Context Impact of ACOs on Physician/Provider Membership Decisions 0 Overview and Legal Context Michael R. Callahan Katten Muchin Rosenman LLP Vice Chair, Medical Staff Credentialing and Peer Review Practice Group

More information

Medicare Shared Savings Program Quality Measure Benchmarks for the 2015 Reporting Year

Medicare Shared Savings Program Quality Measure Benchmarks for the 2015 Reporting Year Medicare Shared Savings Program Quality Measure Benchmarks for the 2015 Reporting Year Release Notes/Summary of Changes (February 2015): Issued correction of 2015 benchmarks for ACO-9 and ACO-10 quality

More information

The Next Shiny Object: Understanding Accountable Care Organizations in the PCMH and Meaningful Use Context

The Next Shiny Object: Understanding Accountable Care Organizations in the PCMH and Meaningful Use Context The Next Shiny Object: Understanding Accountable Care Organizations in the PCMH and Meaningful Use Context 1 The Next Shiny Object: Understanding Accountable Care Organizations in the PCMH and Meaningful

More information

What keeps you up at night?

What keeps you up at night? HEALTH PRACTICE GROUP APRIL 2011 Saul Ewing Health Practice Group: George W. Bodenger Chair What keeps you up at night? The ACO Proposed Rule: A Need to Know Summary By Karen Palestini SUMMARY On March

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

Additional Information About Accountable Care Organizations

Additional Information About Accountable Care Organizations Additional Information About Accountable Care Organizations For more information, please contact: April 2011 On March 31st, the federal government outlined proposed actions relating to Accountable 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

Iowa Wellness Plan ACO Readiness Application

Iowa Wellness Plan ACO Readiness Application The Accountable Care Organization (ACO) Readiness Application must be submitted and approved by Iowa Medicaid Enterprise (IME) prior to IME processing an ACO Enrollment packet. Readiness Applications must

More information

The Medicare Shared Savings Program

The Medicare Shared Savings Program The Medicare Shared Savings Program Centers for Medicare & Medicaid Services Jonathan Blum, Deputy Administrator & Director, Center for Medicare May 20, 2011 Overview CMS s vision of its ACO program Summary

More information

THE FINAL RULE FOR THE MEDICARE SHARED SAVINGS PROGRAM

THE FINAL RULE FOR THE MEDICARE SHARED SAVINGS PROGRAM THE FINAL RULE FOR THE MEDICARE SHARED SAVINGS PROGRAM The Affordable Care Act authorizes the Centers for Medicare and Medicaid Services (CMS) to establish a Medicare Shared Savings Program that would

More information

Accountable Care Organizations: Principles and Implications for Hospital Administrators

Accountable Care Organizations: Principles and Implications for Hospital Administrators S T U D E N T E S S A Y Accountable Care Organizations: Principles and Implications for Hospital Administrators Andrew Russell Bennett, James Madison University E X E C U T I V E S U M M A R Y With the

More information

II. SHARED SAVINGS PROGRAM AND COST-REDUCTION INCENTIVES

II. SHARED SAVINGS PROGRAM AND COST-REDUCTION INCENTIVES E-ALERT Health Care April 15, 2011 ACCOUNTABLE CARE ORGANIZATION BASICS The Affordable Care Act establishes the Medicare Shared Savings Program ( Program ), which provides for the development of accountable

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

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

Physician Integration Models: ACOs as the Latest and Greatest? David T. Lewis david.lewis@lpnt.net LifePoint Hospitals, Inc.

Physician Integration Models: ACOs as the Latest and Greatest? David T. Lewis david.lewis@lpnt.net LifePoint Hospitals, Inc. Physician Integration Models: ACOs as the Latest and Greatest? David T. Lewis david.lewis@lpnt.net LifePoint Hospitals, Inc. Brentwood, TN Kim Harvey Looney kim.looney@wallerlaw.com Waller Lansden Dortch

More information

Medicare Shared Savings Program Quality Measure Benchmarks for the 2014 Reporting Year

Medicare Shared Savings Program Quality Measure Benchmarks for the 2014 Reporting Year Medicare Shared Savings Program Quality Measure Benchmarks for the 2014 Reporting Year Release Notes/Summary of Changes (February 2015): Issued correction of 2014 benchmarks for ACO-9 and ACO-10 quality

More information

ACO Program: Quality Reporting Requirements. Jennifer Faerberg Mary Wheatley April 28, 2011

ACO Program: Quality Reporting Requirements. Jennifer Faerberg Mary Wheatley April 28, 2011 ACO Program: Quality Reporting Requirements Jennifer Faerberg Mary Wheatley April 28, 2011 Agenda for Today s Call Overview Quality Reporting Requirements Benchmarks/Thresholds Scoring Model Scoring Methodology

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

The true meaning of ACO is Awesome Consulting Opportunities. - The Weekly Standard, 04/12/11. Consultants

The true meaning of ACO is Awesome Consulting Opportunities. - The Weekly Standard, 04/12/11. Consultants Accountable Care Organizations: Proposed Regulations and the Local Landscape May 26, 2011 John Clark, MD, JD Isaac M. Willett Medical Director, Clinical i l Informatics Attorney Indiana University Health

More information

A Closer Look at the Final ACO Rule

A Closer Look at the Final ACO Rule A Closer Look at the Final ACO Rule October 2011 For more information, please contact: On October 20th, the federal government released a final rule and other companion releases relating to Accountable

More information

Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare

Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare December 2010 Using Partial Capitation as an Alternative to Shared Savings to Support Accountable Care Organizations in Medicare CONTENTS Background... 2 Problems with the Shared Savings Model... 2 How

More information

Cms Finally speaks: organization (ACO) proposed regulations and WhaT They mean For anesthesiologists

Cms Finally speaks: organization (ACO) proposed regulations and WhaT They mean For anesthesiologists ANESTHESIA BUSINESS CONSULTANTS SUMMER 2011 VOLUME 16, ISSUE 2 Cms Finally speaks: The accountable Care organization (ACO) proposed regulations and WhaT They mean For anesthesiologists Since the passage

More information

Medicare Shared Savings Program & Accountable Care Organizations. American Osteopathic Association National Member Webinar January 5, 2012

Medicare Shared Savings Program & Accountable Care Organizations. American Osteopathic Association National Member Webinar January 5, 2012 Medicare Shared Savings Program & Accountable Care Organizations American Osteopathic Association National Member Webinar January 5, 2012 Overview AOA Position on Practice Transformation and Integrated

More information

Medicare Shared Savings Program: Accountable Care Organizations final rule Summary

Medicare Shared Savings Program: Accountable Care Organizations final rule Summary Medicare Shared Savings Program: Accountable Care Organizations final rule Summary Table of Contents: Background.......1-2 Executive Summary......2-3 Medicare ACO Eligibility........3 Medicare ACO Structure

More information

Summary. Page 1 of 10

Summary. Page 1 of 10 Final ACO rule adopts ANA recommendations on patient-centered care and nursing leadership Other nursing recommendations acknowledged & integrated to improve ACO success (10-27-2011) Summary ANA is pleased

More information

Effective ACO Compliance

Effective ACO Compliance Effective ACO Compliance HCCA Compliance Institute April 21, 2013 Margaret Hambleton, MBA, CHC, CHPC Sr. Vice President, Chief Compliance Officer St. Joseph Health System 1 Objectives Understand Accountable

More information

Building a Post Acute Network: Care Management and ACOs

Building a Post Acute Network: Care Management and ACOs Building a Post Acute Network: Care Management and ACOs A high level summary of proposed rules for ACOs and the shared savings program most relevant to post acute providers. Prepared By: Kathleen M. Griffin,

More information

Improving Quality of Care for Medicare Patients: Accountable Care Organizations

Improving Quality of Care for Medicare Patients: Accountable Care Organizations DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Improving Quality of Medicare Patients: Overview The Centers for Medicare & Medicaid Services (), an agency within the Department

More information

Improving Quality of Care for Medicare Patients: Accountable Care Organizations

Improving Quality of Care for Medicare Patients: Accountable Care Organizations DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services Improving Quality of Care for Medicare Patients: FACT SHEET Overview http://www.cms.gov/sharedsavingsprogram On October

More information

CMS proposed rule on ACOs: http://www.gpo.gov/fdsys/pkg/fr-2011-04-07/pdf/2011-7880.pdf

CMS proposed rule on ACOs: http://www.gpo.gov/fdsys/pkg/fr-2011-04-07/pdf/2011-7880.pdf April 7, 2011 Dear Physician Colleague: On March 31, 2011, the Centers for Medicare & Medicaid Services (CMS) issued its long awaited proposed regulations on the Medicare Shared Savings/Accountable Care

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

Ober Kaler ACO Update

Ober Kaler ACO Update October 27, 2011 Ober Kaler ACO Update CMS Provides Final Framework for ACO and Shared Savings Program Rules: ACO Participants Get Greater Flexibility CMS s final regulations (final rule) implementing

More information

Care Coordination and Contracting Entities: The CHC Perspective on IPAs and ACOs. Today s Discussion

Care Coordination and Contracting Entities: The CHC Perspective on IPAs and ACOs. Today s Discussion Care Coordination and Contracting Entities: The CHC Perspective on IPAs and ACOs Ohio Association of Community Health Centers June 2014 Contact Us Andrew Principe PO Box 410221, Cambridge, MA 02141 P.

More information

ACO Type Initiatives

ACO Type Initiatives If you proposed an ACO initiative, please fill our this Comparison of Elements for Participation in Medicare Shared Savings Program (MSSP) to State SIM ACO Test Proposal From Funding Opportunity Announcement:

More information

CPCA California Primary Care Association

CPCA California Primary Care Association CPCA California Primary Care Association Accountable Care Organizations: Next Generation Systems for Community Health Centers? CPCA Annual Conference Sacramento, California October 10, 2014 Larry Garcia,

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

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

CMS s framework for Value Modifier

CMS s framework for Value Modifier CMS s framework for Value Modifier Relationship between quality of care, cost composites and the Value Modifier Clinical Care Patient Experience Population/ Community Health Patient Safety Care Coordination

More information

Brief Course. Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs

Brief Course. Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs Accountable Care Organization (ACO) 101 Brief Course Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs What is an ACO? ACO refers to a legal entity composed of a group of providers that assume

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

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 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

The Controversial Draft Medicare ACO Regulations: Analysis, Comments and Recommended Action

The Controversial Draft Medicare ACO Regulations: Analysis, Comments and Recommended Action The Controversial Draft Medicare ACO Regulations: Analysis, Comments and Recommended Action June 2, 2011 Boston Brussels Chicago Düsseldorf Houston London Los Angeles Miami Milan Munich New York Orange

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

Chapter Three Accountable Care Organizations

Chapter Three Accountable Care Organizations Chapter Three Accountable Care Organizations One of the most talked-about changes in health care delivery in recent decades is Accountable Care Organizations, or ACOs. Having gained the attention of both

More information

Federal Health Care Reform: Implications for Hospital and Physician partnerships. Walter Kopp Medical Management Services

Federal Health Care Reform: Implications for Hospital and Physician partnerships. Walter Kopp Medical Management Services Federal Health Care Reform: Implications for Hospital and Physician partnerships Walter Kopp Medical Management Services Outline Overview of federal health reform legislation Implications for Care delivery

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

Summary of Medicare Shared Savings Program Final Rule on Accountable Care Organizations

Summary of Medicare Shared Savings Program Final Rule on Accountable Care Organizations Summary of Medicare Shared Savings Program Final Rule on Accountable Care Organizations On November 2, 2011, the Centers for Medicare and Medicaid Services ( CMS ) published a Final Rule implementing the

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

PHI IN THE ACO. Risk Management, Mitigation and Data Collection Issues. Online Tech Webinar May 20, 2014. Tatiana Melnik, Attorney Melnik Legal PLLC

PHI IN THE ACO. Risk Management, Mitigation and Data Collection Issues. Online Tech Webinar May 20, 2014. Tatiana Melnik, Attorney Melnik Legal PLLC PHI IN THE ACO Risk Management, Mitigation and Data Collection Issues Online Tech Webinar May 20, 2014 Tatiana Melnik, Attorney Melnik Legal PLLC Carrie Nixon, Attorney, CEO Nixon Law Group Healthcare

More information

CMS-1461-P Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations

CMS-1461-P Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations February 6, 2015 Ms. Marilyn Tavenner Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services 7500 Security Boulevard Baltimore, Maryland 21244 RE: CMS-1461-P Medicare

More information

June 6, 2011. Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8013 Baltimore, MD 21244-8013

June 6, 2011. Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8013 Baltimore, MD 21244-8013 SUBMITTED ELECTRONICALLY AT http://www.regulations.gov June 6, 2011 Centers for Medicare & Medicaid Services Department of Health and Human Services P.O. Box 8013 Baltimore, MD 21244-8013 Re: CMS-1345-P

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

Advancing Risk Capability in 2015: Medicare Shared Savings Program

Advancing Risk Capability in 2015: Medicare Shared Savings Program Advancing Risk Capability in 2015: Medicare Shared Savings Program Educational Slides for 2016 Class DHG is the firm that BPA has used to help determine the distribution methodologies for our previous

More information

ACOs: Impacting the Past, Present and Future State of Healthcare

ACOs: Impacting the Past, Present and Future State of Healthcare ACOs: Impacting the Past, Present and Future State of Healthcare Article By Alan Cudney, RN, CPHQ, PMP, FACHE, Executive Consultant October 2012 What are Accountable Care Organizations? Can they help us

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

Medicare Shared Savings Program

Medicare Shared Savings Program Medicare Shared Savings Program Eastern Michigan Chapter of HFMA Insurance and Reimbursement Committee April 30, 2015 Presenter: Kenneth B. Lipan, FHFMA Director of Finance: Clinical Integration, Unified

More information

Medicare accountable care organization (ACO) update

Medicare accountable care organization (ACO) update Medicare accountable care organization (ACO) update April 4, 2013 David Glass and Jeff Stensland Today s presentation Background Description of ACO models in Medicare Strengths and weaknesses of ACOs vs.

More information

OUR ACCOUNTABLE CARE ORGANIZATION (ACO) STRATEGY. Meredith Marsh Director Health Choice Care, LLC

OUR ACCOUNTABLE CARE ORGANIZATION (ACO) STRATEGY. Meredith Marsh Director Health Choice Care, LLC OUR ACCOUNTABLE CARE ORGANIZATION (ACO) STRATEGY Meredith Marsh Director Health Choice Care, LLC HEALTH REFORM The Affordable Care Act (ACA) strives to achieve the Triple AIM: Improving the experience

More information

Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View

Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View Medicare and Commercial Accountable Care Organizations: A Retrospective and Prospective View Troy Barsky, Esq. Jennifer Williams, Esq. Crowell & Moring Daniel Murphy, Esq. Bradley Arant Boult & Cummings

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

Issue Brief. CMS Finalizes Rules for Medicare Shared Savings Program (ACOs) KEY POINTS COMMENT

Issue Brief. CMS Finalizes Rules for Medicare Shared Savings Program (ACOs) KEY POINTS COMMENT Issue Brief 4712 Country Club Drive Jefferson City, MO 65109 P.O. Box 60 Jefferson City, MO 65102 573/893-3700 www.mhanet.com FEDERAL ISSUE BRIEF June 5, 2015 KEY POINTS z More than 400 accountable care

More information

AGENCY-SPECIFIC PLAN FOR THE NATIONAL QUALITY STRATEGY

AGENCY-SPECIFIC PLAN FOR THE NATIONAL QUALITY STRATEGY AGENCY-SPECIFIC PLAN FOR THE NATIONAL QUALITY STRATEGY Adult Medicaid Quality Grants Program The Adult Medicaid Quality Grants Program is a 2-year funding opportunity designed to support grantee Medicaid

More information

BAKER DONELSON BAKER S DOZEN

BAKER DONELSON BAKER S DOZEN Thirteen Things Health Care Providers Should Know About Accountable Care Organizations and Health Reform Thomas E. Bartrum, 615.726.5641, tbartrum@bakerdonelson.com With passage of the Patient Protection

More information

The Internal Revenue Service (IRS) is considering the application of the. provisions of the Internal Revenue Code (Code) governing tax-exempt bonds to

The Internal Revenue Service (IRS) is considering the application of the. provisions of the Internal Revenue Code (Code) governing tax-exempt bonds to Part III - Administrative, Procedural, and Miscellaneous Private business use of tax-exempt bond financed facilities Notice 2014-67 SECTION 1. INTRODUCTION The Internal Revenue Service (IRS) is considering

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

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

Quality Scores Monitoring and Reporting

Quality Scores Monitoring and Reporting Section 5.1 Maintain Quality Scores Monitoring and Reporting This tool describes potential quality measurement and performance requirements for a communitybased care coordination (CCC) program, the process

More information

Accountable Care Organizations and the DME Industry Why are we here talking about accountable care???

Accountable Care Organizations and the DME Industry Why are we here talking about accountable care??? Accountable Care Organizations and the DME Industry Alan Morris Director Alternate Care Programs The VGM Group Why are we here talking about accountable care??? This is why.. Federal Council of Economic

More information

MSSP ACO Program Proposed Rule

MSSP ACO Program Proposed Rule MSSP ACO Program Proposed Rule Executive Summary, December 2014 Accountable Care Organization Task Force AUTHORS Vinay Bhupathy* Jay E. Gerzog Kenneth Yood Lynsey Mitchel Eugene Y.C. Ngai Matthew J. Goldman

More information