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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 359<br />

c. Further Consideration<br />

The impact analysis shown is only for the first 3-year agreement period. Beyond this<br />

initial period, there is additional uncertainty, in significant part because the rules governing<br />

subsequent Shared Savings Program agreement periods have not yet been developed. A risk<br />

exists that by <strong>ACO</strong>s in low-cost areas could dominate the Shared Savings Program, where<br />

participation could be a relatively risk-free opportunity to achieve shared savings simply due to<br />

the generous benchmark presented by national average "flat-dollar" growth. On the other hand,<br />

the first 3-year agreement period <strong>ACO</strong>s could foster significant improvements in the quality and<br />

cost-efficiency <strong>of</strong> health care delivery, leading to broader use <strong>of</strong> these techniques nationwide and<br />

accelerated adoption <strong>of</strong> risk-sharing arrangements (such as partial capitation, bundled payments,<br />

etc.). These changes could result in significant efficiency gains in FFS Medicare. The stochastic<br />

model for the first 3 years <strong>of</strong> the program, does not incorporate either <strong>of</strong> these longer-run<br />

scenarios, but both remain possibilities—subject to the final program design and implementation.

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