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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 343<br />

Shared Savings Program and the PGP demonstration, we will provide for unique assignment <strong>of</strong><br />

beneficiaries by ensuring there is no overlap in participating Medicare-enrolled TINs as<br />

mentioned previously.<br />

We believe it is appropriate to consider what transition process should be available for<br />

those PGP demonstration sites that wish to participate in the Shared Savings Program. We do<br />

not believe that automatically transferring the PGP demonstration sites into the Shared Savings<br />

Program is appropriate because we are concerned that some <strong>of</strong> the PGP demonstration<br />

participants may be incapable <strong>of</strong> meeting the Shared Savings Program's requirements, thereby<br />

jeopardizing the participant's ability to achieve the overall goals associated with the Shared<br />

Savings Program, including the ability to achieve shared savings. On the other hand, requiring<br />

the PGP sites to undergo the same application process as all other entities would not account for<br />

our familiarity with these organizations, and their experience with redesigning care processes<br />

and improving quality in a shared savings setting. In addition, requiring the sites to undergo the<br />

full application process could potentially deter qualified sites that are currently participating in<br />

the PGP demonstration from transitioning from the PGP demonstration to the Shared Savings<br />

Program.<br />

We propose that should a PGP site decide to apply for participation to the Shared Savings<br />

Program, we will give the site the opportunity to complete a condensed application form. The<br />

condensed application form would require the applicant to provide the information that is<br />

required for the standard Shared Savings Program application but that was not already obtained<br />

through its application for or via its participation in the PGP demonstration and, if necessary, to<br />

update any information contained in its application for the PGP demonstration that is also<br />

required on the standard Shared Savings Program application. For instance, the condensed

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