Based on experiences of the Premier ACO Collaborative, involving more than 80 hospitals, Premier has proposed a variety of regulations for accountable care organizations in a letter to CMS, according to a report by Premier.
The recommendations come at a time when CMS is drafting proposed ACO rules, expected to be released before the end of the year. Here are 10 sample recommendations from the Premier report, which summarizes the company's 43-page letter to CMS.
1. Encourage multiple ACOs in each market. CMS should take steps to encourage more than one ACO in an area. "Multiple ACOs will enhance competition to drive even better results for beneficiaries and Medicare," the summary stated.
2. Fully recognize hospital-based ACOs. While the healthcare reform law focused on ACOs led by physicians, CMS should also recognize "ACOs formed by hospitals and those where hospitals and physicians have a contractual relationship," the summary stated. "In many cases the hospital will be the only entity with sufficient infrastructure, staff, capital risk-tolerance and other resources needed to drive large-scale change."
3. Allow a variety of payment models. CMS should consider accepting applications in the ACO program for shared savings, bundled payments, capitation or a combination of these models.
4. Assign beneficiaries to primary care physicians. Beneficiaries should first be "mapped" (a form of assignment) to a primary care physician or ACO professional. Otherwise, beneficiaries would be assigned to the specialists they saw the most, for at two visits.
5. Initially allow a higher savings share. CMS should initially share 70-80 percent of savings. "Providers will have to invest significant resources in the first few years to transform their structures and processes, and should be compensated for this dramatic effort and risk," the summary said.
6. Create separate payment pools for efficiency, quality. From shared savings, create a pool to reward efficiency and another pool to reward quality. Over time, the quality pool should be weighted more heavily to represent a larger portion of the pool.
7. Allow capitation models. CMS should allow partial and full capitation models from the start of the program. "CMS should not specify in advance the services that must be included in such a model, nor should it require all services to be included," the summary said.
8. Protect ACOs from antitrust enforcement. Any ACO that receives a Medicare ACO contract from CMS should be viewed as clinically and financially integrated for antitrust purposes in the private sector as well as for Medicare and Medicaid.
9. Allow hospitals more generous funding of practices' IT, etc. "The existing, narrowly constructed exceptions that allow for one provider entity to fund the infrastructure costs of another are narrowly defined and need to be broadened for the ACO program," the summary stated.
10. Allow role for children's hospitals. "ACOs should be able to integrate non-exclusive participation by certain specialty providers, such as children’s hospitals, in an ACO without creating market power concerns," the summary stated.
Read the Premier summary on ACOs.
Read more on ACOs:
-Accountable Care: The Top Five Things the Community Hospital Can Do Now
-Is Your Organization Ready For Accountable Care? How to Implement a Readiness Assessment and Establish Priorities
-7 Thoughts on How Antitrust Laws Could be Changed to Accommodate ACOs
The recommendations come at a time when CMS is drafting proposed ACO rules, expected to be released before the end of the year. Here are 10 sample recommendations from the Premier report, which summarizes the company's 43-page letter to CMS.
1. Encourage multiple ACOs in each market. CMS should take steps to encourage more than one ACO in an area. "Multiple ACOs will enhance competition to drive even better results for beneficiaries and Medicare," the summary stated.
2. Fully recognize hospital-based ACOs. While the healthcare reform law focused on ACOs led by physicians, CMS should also recognize "ACOs formed by hospitals and those where hospitals and physicians have a contractual relationship," the summary stated. "In many cases the hospital will be the only entity with sufficient infrastructure, staff, capital risk-tolerance and other resources needed to drive large-scale change."
3. Allow a variety of payment models. CMS should consider accepting applications in the ACO program for shared savings, bundled payments, capitation or a combination of these models.
4. Assign beneficiaries to primary care physicians. Beneficiaries should first be "mapped" (a form of assignment) to a primary care physician or ACO professional. Otherwise, beneficiaries would be assigned to the specialists they saw the most, for at two visits.
5. Initially allow a higher savings share. CMS should initially share 70-80 percent of savings. "Providers will have to invest significant resources in the first few years to transform their structures and processes, and should be compensated for this dramatic effort and risk," the summary said.
6. Create separate payment pools for efficiency, quality. From shared savings, create a pool to reward efficiency and another pool to reward quality. Over time, the quality pool should be weighted more heavily to represent a larger portion of the pool.
7. Allow capitation models. CMS should allow partial and full capitation models from the start of the program. "CMS should not specify in advance the services that must be included in such a model, nor should it require all services to be included," the summary said.
8. Protect ACOs from antitrust enforcement. Any ACO that receives a Medicare ACO contract from CMS should be viewed as clinically and financially integrated for antitrust purposes in the private sector as well as for Medicare and Medicaid.
9. Allow hospitals more generous funding of practices' IT, etc. "The existing, narrowly constructed exceptions that allow for one provider entity to fund the infrastructure costs of another are narrowly defined and need to be broadened for the ACO program," the summary stated.
10. Allow role for children's hospitals. "ACOs should be able to integrate non-exclusive participation by certain specialty providers, such as children’s hospitals, in an ACO without creating market power concerns," the summary stated.
Read the Premier summary on ACOs.
Read more on ACOs:
-Accountable Care: The Top Five Things the Community Hospital Can Do Now
-Is Your Organization Ready For Accountable Care? How to Implement a Readiness Assessment and Establish Priorities
-7 Thoughts on How Antitrust Laws Could be Changed to Accommodate ACOs