(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 118
disclosures are consistent with the purpose for which the data discussed in this rule was
collected, and thus, should not run afoul of the Privacy Act, provided we ensure that an
appropriate Privacy Act system of records "routine use" is in place prior to making any
disclosures.
Therefore, at the beginning of the agreement period, at the request of the ACO,
we are proposing to provide the ACO with a list of beneficiary names, date of birth, sex,
and HICN derived from the assignment algorithm used to generate the 3-year benchmark.
As discussed in section II.B. of this proposed rule, these are beneficiaries who received
the plurality of primary care services from primary care physicians who are ACO
participants. We seek comment on this proposal and on whether and how this
information would be beneficial to the goals of improved care coordination and
improving care delivery for the ACO's assigned beneficiary population.
6. Sharing Beneficiary-Identifiable Claims Data
While the availability of aggregate beneficiary information and the identification
of the beneficiaries used to determine the benchmark should assist ACOs in the overall
redesign of care processes and coordination of care for their assigned beneficiary
populations, we believe that more complete beneficiary-identifiable information would
enable practitioners in an ACO to better coordinate and target care strategies towards the
individual beneficiaries who may ultimately be assigned to them. For example, knowing
which beneficiaries have frequent emergency department visits could help the ACO
develop systems to ensure these beneficiaries have timely access to office-based care.
The PGP demonstration provided beneficiary identifiable claims data to the
participating sites but the beneficiary identifiable claims data that was provided was the