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BESLER Responds to CMS Request for Comments on ACO Regulations


In the November 17, 2010 Federal Register, the Centers for Medicare & Medicaid Services (“CMS”) issued a request for comments regarding the upcoming proposed regulations for accountable care organizations (“ACOs”) and the Medicare Shared Saving Program as described in Patient Protection and Affordable Care Act.

BESLER Consulting responded to the request and made the following recommendations:  

  • Encourage the inclusion of solo and small group physician practices in ACOs, as 75% to 80% of physicians practice in these settings
  • Notify beneficiaries of their inclusion in an ACO at the time they are assigned to one
  • Consider allowing beneficiaries to participate in the shared savings of an ACO in order to encourage better compliance with determined plans of care
  • Develop patient-centeredness criteria that encourage communication of the medical implications of diagnosis and treatment as well as the related costs
  • Pursue a flexible and focused approach to assess beneficiary and caregiver experience of care in ACOs
  • Utilize quality of care measures and benchmarks that are consistent with existing industry standards and establish quality improvement programs
  • Consider a number of additional payment models for ACOs.

The full text of the BESLER response letter can be found here.

CMS recently indicated that the proposed regulations regarding ACOs will be released in mid January or later.  BESLER will keep its clients informed of the latest developments in this area as they unfold.