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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 215<br />

(Option 1) but using a threshold approach (Option 2) when calculating losses so that higher<br />

quality does not reduce an <strong>ACO</strong>'s share <strong>of</strong> any losses. Such an approach would have the effect<br />

<strong>of</strong> essentially applying a minimum sharing rate for losses (for example, 50 percent) and could<br />

appropriately reflect the goal <strong>of</strong> the Shared Savings Program to reward high quality and efficient<br />

care, by providing a greater reward when high quality care is also efficient and less relief for<br />

high quality care that is not efficient. Alternatively, the threshold option could be utilized in the<br />

two sided model so that if the threshold score for the two sided model resulted in 60% shared<br />

savings, it would also result in 60 percent shared losses, creating a symmetrical two-sided model.<br />

Another example <strong>of</strong> a blended approach would be to use the threshold approach (Option 2) for<br />

the first 3 years <strong>of</strong> the Shared Savings Program and then, as experience is gained and measures<br />

are further aligned, transition to performance scoring (Option 1). We also invite comment on the<br />

proposal to set the quality performance standard <strong>of</strong> the first program year at the reporting level<br />

and to raise the standard to reflect performance in subsequent years. We also invite comment on<br />

the proposed quality measures scoring methodologies under the one-sided and two-sided risk<br />

models. In addition, we invite comment on our proposal to have all quality measures listed in<br />

Table 1 required <strong>of</strong> all <strong>ACO</strong>s, and the alternative under which <strong>ACO</strong>s would be required to only<br />

report a subset <strong>of</strong> the measures in Table 1, based on their level <strong>of</strong> readiness for the Shared<br />

Savings Program.<br />

5. Incorporation <strong>of</strong> Other Reporting Requirements related to the Physician Quality Reporting<br />

System and Electronic Health Records Technology Under Section 1848 <strong>of</strong> the Act<br />

Medicare provides multiple incentive payment options for providers to report and use<br />

clinical information more proactively in their practices. The Affordable Care Act gives the<br />

Secretary authority to incorporate reporting requirements and incentive payments from these

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