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Supportive of intent of ACO proposed rule, ACP expresses concern
Date:6/2/2011

for ACOs participating in the Medicare Shared Savings Program, which may be attractive to ACOs organized around smaller practices, and will be providing separate comments on this option. We believe there are a substantial number of physician practice collaborations of varying size, particularly those already providing primary care services that have achieved or are prepared to achieve recognition as qualified Patient-Centered Medical Homes, that would now or in the near future be interested in exploring the possibility of partnering with CMS within a shared saving payment structure; but the current requirements make such a consideration impractical. This is unfortunate. It is the hope of ACP that through suggested changes within the proposed rule, and/or through new initiatives through the CMMI, there will be an increased opportunity for a wider scope of physician practices to participate under the new payment model.

To address this shortcoming, the College recommends that CMS create a pathway for practices of varying sizes and level of practice transformation to participate in ACOs, including offering a "laddered" approach to participation, providing a true "up side" shared savings option where participating entities will be able to share in any saving compared to the established benchmark but will not be expected to share in any losses, and reducing the burdens on physicians of reporting on quality measures. ACP also supported the proposed rule's strong emphasis on primary care, but recommended a prospective patient attribution methodology based on the primary care physicians who provide the plurality of patient care (with changes to ensure that primary care physicians who see patients in the hospital or offer ancillary services are not excluded), and counting the contributions of internal medicine subspecialists who provide comprehensive primary care in rural and similar underserved healthcare areas in which there are not a sufficient numb
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Contact: David Kinsman
dkinsman@acponline.org
202-261-4554
American College of Physicians
Source:Eurekalert

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