(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 237
beneficiaries during each year of the agreement period and its benchmark (updated,
according to statute as described in more detail later in the document) should reflect how
well the ACO is coordinating care for these beneficiaries and improving the overall
efficiency of their care.
An accurate benchmark estimate is important in order to ensure that an ACO that
successfully coordinates care and achieves real savings is rewarded with shared savings.
Similarly, an accurate benchmark estimate helps to ensure that shared savings are not
inadvertently paid to an ACO that does not successfully coordinate care well or that has
not achieved savings in excess of normal variation in annual expenditures.
We have considered two legally permissible approaches to meeting the statutory
language for estimating the benchmark, which we will call Option 1 and Option 2 in this
proposed rule. Both approaches involve benchmarks that are derived from prior
expenditures of assigned beneficiaries and adjusted for certain beneficiary characteristics,
and other factors, the Secretary determines appropriate and updated by the projected
absolute amount of growth in national per capita expenditures. Under both approaches,
the benchmark would also be reset at the start of each agreement period. However, a key
difference between these two approaches is the beneficiary population used to determine
expenditures for purposes of the benchmark. Specifically, under Option 1, we would
estimate an ACO's benchmark based on the Parts A and B FFS expenditures of
beneficiaries who would have been assigned to the ACO in each of the 3 years prior to
the start of an ACO's agreement period using the ACO participants' TINs. In contrast,
under Option 2, the benchmark would be based on the Parts A and B FFS expenditures of
beneficiaries, who are actually assigned to the ACO during each performance year, with