(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 272
and additional increases for including FQHCs and/or RHCs) would be applied to net
savings above this 2 percent threshold in order to determine the shared savings amount.
We believe that this threshold protects the program from sharing unearned savings and
helps to ensure that shared savings are due to enhanced care coordination and quality of
care on the part of the ACO.
As previously discussed, many smaller physician-driven ACOs and ACOs caring
for underserved populations have the potential to improve the quality and efficiency of
care, but may be especially challenged in accessing capital to meet their needs. We hope
to encourage successful participation by these ACOs in the Shared Savings Program.
Additionally, we acknowledge that providers/suppliers working in these environments
face additional challenges in coordinating care and creating the infrastructure necessary
to create a successful ACO, and therefore may not be equipped to assume the risk right
away (and be eligible for greater reward) of the two-sided model. As such, we are
proposing that ACOs that meet the following criteria would be exempt from the 2 percent
net savings threshold and would instead share on first dollar savings under the one-sided
model. We propose to exempt ACOs with less than 10,000 assigned beneficiaries in the
most recent year for which we have complete claims data (for instance, 2012 for 2014
program participation) and that meet one of the following:
• The ACO is comprised only of ACO professionals in group practice
arrangements or networks of individual practices of ACO professionals.
• 75 percent or more of the ACO's assigned beneficiaries reside in counties
outside a Metropolitan Statistical Area (MSA) in the most recent year for which we have
complete claims data.