(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 46
ACO participant in an ACO containing one or more of the statutory organizations eligible
to form an ACO (as specified in section 1899(b)(1)(A)-(D) of the Act) and upon which
assignment can be made consistent with the statute and the assignment methodology
proposed in section II.D. of this proposed rule. However, we note that even in this case,
for the reasons stated previously, we would not have the data necessary to consider
FQHC or RHC patients in the assignment process. Thus, assignment of beneficiaries to
ACOs in which FQHCs and RHCs are participating would have to be based solely on
data from the other eligible ACO participants upon whom assignment can be based. As
the Shared Savings Program develops, we will continue to assess the possibilities for
collecting the requisite data from FQHCs and RHCs, and in light of any such
developments we will consider whether it is possible at some future date for Medicare
beneficiaries to be assigned to an ACO on the basis of services furnished by an FQHC or
RHC, thereby allowing these entities to have their Medicare beneficiaries included in the
ACO's assigned population.
The situation is somewhat more complicated with regard to CAHs. Section
1834(g) of the Act provides for two payment methods for outpatient CAH services.
Under the method specified in section 1834(g)(1) of the Act (referred to as the
standard method), facility services are paid at 101 percent of reasonable costs to the CAH
through the Medicare fiscal intermediary or the Medicare Part A/B MAC, while
payments for physician and other professional services are made separately to the
physician or other practitioner under the MPFS through Medicare carriers. Accordingly,
CAHs that bill under the standard method would not submit claims with information on