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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 208<br />

previously, we propose calculating the percentage <strong>of</strong> points an <strong>ACO</strong> earns for each domain by<br />

dividing the points earned by the total points available, yielding a percentage. For example, if an<br />

<strong>ACO</strong> earns 16.2 out <strong>of</strong> 18 points in the preventive health domain, the <strong>ACO</strong> earned 90 percent <strong>of</strong><br />

the points for the preventive health domain (16.2 divided by 18 equals .90). Assuming the <strong>ACO</strong><br />

is operating under the two-sided shared savings model and earns 90 percent <strong>of</strong> the quality<br />

performance points across all five domains and generates shared savings, it would receive 90<br />

percent <strong>of</strong> the <strong>ACO</strong>'s share <strong>of</strong> the savings or 54 percent <strong>of</strong> the total savings generated. That is,<br />

achieving 90 percent <strong>of</strong> the potential 60 percent <strong>of</strong> shared savings an <strong>ACO</strong> can earn under the<br />

two-sided model, means the <strong>ACO</strong> could earn 54 percent <strong>of</strong> the total savings generated. Under<br />

the one-sided model, achieving 90 percent <strong>of</strong> the potential 50 percent <strong>of</strong> shared savings, means<br />

the <strong>ACO</strong> could earn 45 percent <strong>of</strong> the shareable savings generated.<br />

Under both the one-sided and two-sided shared savings models, the quality measures<br />

domain scoring methodology treats all domains equally regardless <strong>of</strong> the number <strong>of</strong> measures<br />

within the domain. We believe the key benefit <strong>of</strong> weighting the domains equally is that it does<br />

not create a preference for any one domain, which we believe is important as we expect <strong>ACO</strong>s to<br />

vary in composition, and, as a result, to place more emphasis on different domains. We also<br />

considered weighting the domains to emphasize priority conditions or areas in order to<br />

emphasize (or de-emphasize) certain measures that are more difficult (or easy) to achieve<br />

without needing to change the scoring methodology. This method would require judgment about<br />

which domains are more important than others, which may not be appropriate. Equal weighting<br />

contains an implicit judgment that domains such as patient/caregiver experience <strong>of</strong> care and<br />

patient safety are equally important to the quality <strong>of</strong> care. Accordingly, we believe <strong>ACO</strong>s should<br />

seek to address all aspects <strong>of</strong> patient care in order to improve the overall quality <strong>of</strong> care under the

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