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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 362<br />

measures. Further analysis is provided in the Physician Group Practice Demonstration<br />

Evaluation Report (Report to Congress, 2009;<br />

http://www.cms.gov/DemoProjectsEvalRpts/downloads/PGP_RTC_Sept.pdf).<br />

In addition to the overall increases in quality scores, we can examine the impact <strong>of</strong> the<br />

PGP Demonstration on quality can be examined by comparing the values <strong>of</strong> the seven<br />

claimsbased quality measures for each PGP site and its comparison group. Our analysis found<br />

that, on the claims-based measures, PGP performance exceeded that <strong>of</strong> the comparison groups<br />

(CGs) on all measures between the base year (BY) and performance year 2 (PY2). It also found<br />

that the PGP sites exhibited more improvement than their CGs on all but one measure between<br />

the BY and PY2. Even after adjusting for pre-demonstration trends in the claims-based quality<br />

indicators, the PGP sites improved their claims-based quality process indicators more than their<br />

comparison groups.<br />

3. Impact on Providers and Suppliers<br />

In order to participate in the program, we realize that there will be costs borne in building<br />

the organizational, financial and legal infrastructure that is required <strong>of</strong> an <strong>ACO</strong> as well as<br />

performing the tasks required (as discussed throughout the Preamble) <strong>of</strong> an eligible <strong>ACO</strong>, such<br />

as: quality reporting, conducting patient surveys and investment in infrastructure for effective<br />

care coordination. While provider and supplier participation in the Shared Savings Program will<br />

be voluntary, we have examined the potential costs that program participation will create.<br />

The proposed rule allows for flexibility regarding the specific structure <strong>of</strong> an <strong>ACO</strong> and,<br />

as such, we expect the costs to vary greatly. Furthermore, beyond the statutorily required<br />

assignment <strong>of</strong> at least 5,000 Medicare beneficiaries to an <strong>ACO</strong>, the size <strong>of</strong> <strong>ACO</strong>s will also vary<br />

in relation to beneficiary participation and associated cost. Due to the limited precedence for this

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