Accountable care organizations will be unsuccessful from the start without “dramatic changes” to the CMS' proposed rule on these entities, according to the American Medical Group Association, which represents nearly 400 multi-specialty groups and integrated health systems.
AMGA: 'Dramatic' ACO rule changes needed
In the AMGA's public comment (PDF) letter, the group endorsed the ACO model but said the CMS has "created a design specification encompassing onerously complex application and participation requirements coupled with unbalanced risk/reward criteria that disadvantages ACO entities."
The AMGA remarked on more than a dozen areas of the rule, offering feedback on the application process, patient assignment, quality reporting, risk adjustment and the minimum savings rate. The group also urged the CMS to make provisions and changes to data-gathering that will let federally qualified health centers and rural health centers become ACOs on their own.
In addition, the proposed rule's call for providers to meet 65 quality measures is unreasonable, according to the AMGA. Instead, quality measures should be limited to no more than 32 and should be phased in over a three-year period.
And rather than opting for just a two-sided risk model, the CMS should offer several participation tracks, including one that would be a shared-risk-only approach.
“The shared savings rate should vary depending on the risk/reward criteria in the tracks, e.g., 70% in track one with no downside risk and 80% in track two, a two-sided option," according to the letter.
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