(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 95
Individualized plans of care are not only an integral part of providing quality
health care to both high-risk patients or patients with multiple chronic conditions, but are
equally important in proactively maintaining the health for any beneficiary. For purposes
of the application to participate in the Shared Savings Program, we propose that an ACO
would be required to submit a description of its individualized care program, along with a
sample care plan, and explain how this program is used to promote improved outcomes
for, at a minimum, their high-risk and multiple chronic condition patients. In addition,
the ACO should describe additional target populations that would benefit from
individualized care plans. We also propose that ACOs be required to describe how they
will partner with community stakeholders as part of their application. ACOs that have a
stakeholder organization serving on their governing body would be deemed to have
satisfied this requirement. We request comment on these proposals. We are specifically
interested in whether these requirements will create disincentives for participation among
smaller entities.
11. ACO Marketing Guidelines
We believe there is a potential for beneficiaries to be misled about Medicare
services available from an ACO or about the providers and suppliers from whom they can
receive those services. We realize that care coordination is an important component of the
Shared Savings Program; however, the potential for shared savings may be an incentive
for ACOs, ACO participants, or ACO providers/suppliers to engage in behavior that may
confuse or mislead beneficiaries about the Shared Savings Program or their Medicare
rights. For example, although it is expected that ACO providers/suppliers participating in
an ACO will refer patients to other ACO providers/suppliers in the ACO, we are