(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 260
provides a stronger incentive for ACO development in areas with historically lower
expenditures and growth rates. Conversely, potential ACOs in areas with historically
higher growth rates could be reluctant to participate in the program because the challenge
to reduce their growth rate would be greater in these areas relative to low expenditure,
low growth ones.
On balance, we believe that for purposes of establishing an initial expenditure
benchmark, expenditures should be trended forward in a relatively neutral and
comparable way across geographic areas. Therefore, we are proposing to trend forward
the most recent 3 years of per-beneficiary expenditures using growth rates in per
beneficiary expenditures for Parts A and B services. For example, we would use 2011,
2012 and 2013 claims year data to set the benchmark for an ACO starting its agreement
period in 2014. The 2011 and 2012 data would be trended forward using the factor
described later in this proposed rule so that all benchmark dollars would be in 2013
dollars. We welcome comments on this proposal, and especially on whether the other
option that we considered to trend the benchmark by the flat dollar amount would be
more consistent with our proposal to update the benchmark as specified under section
1899(d)(1)(B)(ii), as discussed in the next section.
b. National vs Local Growth Rate as a Benchmark Trending Factor
Under the option described previously, we could trend per beneficiary
expenditures forward using national or local growth factors. Using the national growth
rate in Medicare A and B FFS expenditures would appear to be more consistent with the
methodology that, as specified in section 1899(d)(1)(B)(ii) of the Act incorporates the
absolute amount of growth in per capita expenditures for Medicare Parts A and B