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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 221<br />

proposing greater alignment between the Shared Savings Program and the EHR Incentive<br />

program through future rulemaking. We considered several other options for incorporating other<br />

program reporting requirements into the Shared Savings Program. One option was to<br />

incorporate Physician Quality Reporting System into the Shared Savings Program via a scaled<br />

approach, in which how the <strong>ACO</strong> performs on the quality measures under the Shared Savings<br />

Program would determine the amount <strong>of</strong> Physician Quality Reporting System incentive an <strong>ACO</strong><br />

could earn. However, we thought this approach would be burdensome and confusing to providers<br />

who are used to a different approach under the traditional Physician Quality Reporting System.<br />

We also considered proposing to limit incorporation <strong>of</strong> the Physician Quality Reporting System<br />

incentive under the Shared Savings Program to the <strong>ACO</strong>'s group practices that were used for<br />

beneficiary assignment rather than to all group practices associated with an <strong>ACO</strong>. However, we<br />

thought expanding the Physician Quality Reporting System incentive under the Shared Savings<br />

Program to all participant TINs within an <strong>ACO</strong> would be more efficient for EPs participating in<br />

both traditional Physician Quality Reporting System and the Physician Quality Reporting System<br />

and the Physician Quality Reporting System incentive under the Shared Savings Program. This<br />

way <strong>ACO</strong>s would report one way for the Physician Quality Reporting System for all <strong>of</strong> its <strong>ACO</strong><br />

providers/suppliers who are eligible pr<strong>of</strong>essionals; that is, for purposes <strong>of</strong> qualifying for the<br />

Physician Quality Reporting System incentive, the <strong>ACO</strong> would not need to report one way for<br />

the TINs used for beneficiary assignment and another way for the TINs not used for assignment.<br />

Another option we considered was to incorporate the eRx Incentive Program's incentive<br />

requirements and payments into the Shared Savings Program. However, we are not proposing to<br />

incorporate the eRx incentive requirements and payments under the Shared Savings Program<br />

since the eRx incentive ends after 2013. We believe it would be burdensome to require <strong>ACO</strong>s to

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