Stakeholders Seek Changes to ACO Shared Savings Program

The National Association of ACOs in a comment letter to the Centers for Medicare and Medicaid Services wants the government to make more patient data available to accountable care organizations in the Medicare Shared Savings Program.

NAACOS wrote the letter in cooperation with numerous other industry stakeholders, who also are sending their own separate comment letters to CMS, based on a proposed rule already issued. The NAACOS letter covers additional issues such as beneficiary assignment, shared savings and losses, payment waivers, resetting benchmarks and required processes to coordinate care.

But more and timelier data to ACOs also is critical to success of Shared Savings, according to the association. “NAACOS believes that additional beneficiary identifiable data should be included in aggregate data reports to enhance the meaningfulness of the information.”

Types of new data that Shared Savings ACOs need include:

* Date of the beneficiary’s original Medicare eligibility,

* Date of change in the beneficiary’s eligibility status,

* An indicator identifying the change of an individual beneficiary’s Health Insurance Claim Number along with the date of change,

* Hierarchal Condition Category score for each beneficiary,

* Opt-out information to the beneficiary attribution file to create a check-and-balance process which will ensure members are not lost in the data reporting process,

* For each beneficiary included on each attribution report an indicator of a beneficiary’s institutional/hospice status which will help ACOs identity domiciled patients for which the ACO is unaware,

* Expand the information subsections for outpatient Part A services and physician services on the quarterly reports to help ACOs manage costs, access, quality and care coordination if physician services were divided into primary care physicians and non-primary care physicians; and,

* Provide aggregated data on substance abuse claims expenditures.

ACOs also seek from CMS data for real-time care coordination, the association tells regulators. “Since Medicare patients have the right to seek care from any provider who accepts Medicare, it can be a challenge for ACOs to monitor the services received by their assigned patients. With respect to applicable laws governing patient privacy and the disclosure of PHI, and since CMS currently receives all eligibility checks from hospitals, emergency departments and post-acute providers, and maintains a real-time file of these eligibility checks, CMS could make this data available to ACOs.”

Getting that data would let a provider know when an ACO beneficiary’s eligibility is being checked, giving a real-time opportunity to coordinate care with the other provider or redirect the patient to another provider.

NAACOS in the letter to CMS offers support for using the 1-800-Medicare phone number to let beneficiaries easily opt out of data sharing. However, those who opt out should be removed from the financial reconciliation process “as this will effectively eliminate the ability for an ACO to coordinate care. ACOs should not be held financially responsible for these beneficiaries.”