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(ACO) regulations - American Society of Anesthesiologists

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CMS-1345-P 77<br />

include provisions for internal assessment <strong>of</strong> cost and quality <strong>of</strong> care within the <strong>ACO</strong>,<br />

and employ these assessments in continuous improvement <strong>of</strong> the <strong>ACO</strong>'s care practices.<br />

The other option is to identify specific criteria that we would propose to require<br />

<strong>ACO</strong>s to meet with regard to each <strong>of</strong> these requirements. For example, with regard to the<br />

requirement to promote evidence-based medicine, we could provide a detailed<br />

description <strong>of</strong> evidence-based guidelines for various conditions and diseases for which<br />

we would hold <strong>ACO</strong>s accountable, including specific instructions for how an <strong>ACO</strong> would<br />

demonstrate it is following these guidelines and monitoring compliance among its <strong>ACO</strong><br />

participants and <strong>ACO</strong> providers/suppliers. We could also specify a number <strong>of</strong> conditions<br />

for which the <strong>ACO</strong> would maintain an evidence-based medicine preventive health<br />

guidelines program. Similarly, we could identify and require the use <strong>of</strong> specific decision<br />

support tools, patient activation measures, or other patient support tools in order for an<br />

<strong>ACO</strong> to satisfy the requirement for beneficiary engagement.<br />

However, we have concerns that a prescriptive approach would be premature and<br />

potentially impede innovation and the goals <strong>of</strong> this program. Thus, for the requirements<br />

under section 1899(b)(2)(G) <strong>of</strong> the Act, we are proposing that in order to be eligible to<br />

participate in the Shared Savings Program, the <strong>ACO</strong> provide documentation in its<br />

application describing its plans to: (1) promote evidence-based medicine; (2) promote<br />

beneficiary engagement; (3) report internally on quality and cost metrics; and (4)<br />

coordinate care. We are proposing this option in order to allow <strong>ACO</strong>s the flexibility to<br />

choose the tools for meeting these requirements that are most appropriate for their<br />

practitioners and patient populations. Over time, as we learn more about successful<br />

strategies in these areas, and as we have more experience assessing specific critical

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