The American Medical Group Association (AMGA), a professional association representing multispecialty medical groups and other organized systems of care, today released its comments on proposed regulations for Medicare's Shared Savings Program, popularly known as Accountable Care Organizations (ACOs). The much-anticipated proposal from the Centers for Medicare and Medicaid Services (CMS) was published on April 7, 2011 and the public comments period concludes today. While AMGA fully supports the accountable care concept, it found the rule wanting in many ways and offered suggestions by which to strengthen it.
"We acknowledge and applaud CMS for its noteworthy activities in providing information about ACOs by broadly inviting comments and suggestions, holding national conference calls, making much information readily available on its website, and dispatching senior CMS officials to talk to stakeholders and interested parties," said Donald W. Fisher, Ph.D., CAE, AMGA's president and chief executive officer. He added: "We want ACOs to work, but the rule as drafted is not going attract much voluntary participation if it isn't dramatically changed in its final version. We offer many suggestions, which, if incorporated into final program design, may make the ACO program more attractive. ACOs if properly structured would set the stage for delivery system transformation from its fragmented state to one of greater effectiveness and efficiency, over time."
Among key changes suggested were: Allowing ACO participants to elect retrospective or prospective patient attribution; lowering the minimum savings rate to 1 percent; allowing a participation track with only shared savings risk assumption; dropping "opt-out" provisions for patient data sharing; increasing the shared savings rate and the maximum payout cap; using risk adjustment in a dynamic fashion, i.e., based on an annual recalculation of population disease acuity, as opposed to the static method put forward; simplification of the application process; moderation of the reinsurance provisions; dropping the number of quality measures required and phasing them in over time; and many others.
The letter, under Fisher's signature, closes with these comments: "…because we feel that this advanced practice model of delivery has long-term potential to redirect and reshape the nation's fragmented health care delivery system, we urge you to significantly change the program design. If this does not happen, participation will be scant and the ACO national implementation runs the risk of ending up inconsequential."
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