(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 245
Of these two methods for adjusting for decedents during the course of the
performance year under Option 2, our preference is for the first method. However, we
invite comments on both of these methods, and any others that might be suggested for
adjusting for decedents during the course of the performance year under Option 2.
The second method is intended to address the implications of changes to an ACO's
population over time, but this option would require additional data adjustments and
computations that are not required under the first method.
However, to the extent that average per capita expenditures for all beneficiaries
differs from the average for the geographic area in which an ACO operates, the first
method previously discussed would effectively be imputing a value that is likely to be
somewhat higher or lower than would actually be expected for that ACO. Alternatively,
excluding the experience of beneficiaries with less than 1 full year of experience from the
shared savings computations as contemplated in the second method previously discussed,
would reduce the size of an ACO's beneficiary population, increasing the MSR that
would be needed before an ACO would be eligible to share savings. This could have the
effect of discouraging participation among smaller ACOs, for example, in rural areas.
Likewise, we would expect a similar impact on an ACO's MSR if deceased beneficiaries
were excluded from the shared savings computations as is previously proposed.
d. Summary
We believe both Option 1 and Option 2 are legally permissible approaches to
setting the expenditure benchmark, adjusting for beneficiary characteristics, and updating
by the projected absolute amount of growth in national per capita expenditures. We also
believe that both approaches can establish viable benchmarks to measure ACO