FTC: How Big Does an ACO Need to be?

Allowing relatively small ACOs would enhance competition, but ACOs that are too small cannot be viable. At an Oct. 5 listening session on accountable care organizations, FTC representatives asked for feedback from a panel of stakeholders on how small ACOs should be.

"The answer is we don’t know," said Harold Miller, president and CEO of the Network for Regional Healthcare Improvement in Pittsburgh. He said more experience is needed and in any case, minimum numbers would vary depending on patient mix. Organizations with healthier patients would need a higher minimum number because there needs to be a sufficient amount of encounters to get feedback about the effectiveness of care measures. Too few members in the ACO would create a "noisy number" subject to variation from year to year, said Dana Gelb Safran, senior vice president for performance measurement and improvement at Blue Cross Blue Shield of Massachusetts.

The healthcare reform law set a minimum of 5,000 Medicare beneficiaries for each ACO, but that number may be too low, especially for private payor ACOs where patients need fewer services, said Lawrence Casalino, MD, chief of the Division of Outcomes and Effectiveness at Weill-Cornell Medical College in New York. He added that if ACOs assume capitated payments, the minimum number of members would have to be even higher because organizations need large volumes to offset potential variations in costs.   

Gloria Austin, CEO of Brown & Tolland Medical Group in San Francisco added that providers who use a patient-centered medical home generally need a minimum of 10,000 members and the approach should be primary care-driven. "We're an overspecialized country," she said. "We've got to face up to that problem."

Panelists also discussed whether ACOs could operate using small groups of doctors organized into independent practice associations or physician-hospital organizations. "Can IPAs and PHO networks with lots of small practices match the ACOs that large multispecialty groups are creating?" Dr. Casalino asked. "We'll have to see."

Ms. Safran said many organizations in Blue Cross of Massachusetts' Alternative QUALITY Contract, an ACO-like arrangement, have brought together practices with five or fewer physicians. Lee Sacks, MD, president of Advocate Physician Partners, said his organization has groups of similar sizes.

AMA President Cecil Wilson observed the discussion was focused on populated areas. While having more than one ACO in an area encourages competition, it may be difficult to organize even one ACO in some rural areas, he said.

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