The Integrated Healthcare Association, a stakeholder group in California, is calling on the Centers for Medicare and Medicaid Services to cut in half the number of performance measures during the first year of the Medicare Shared Savings Program.

In a comment letter to CMS, the association contends that complying with the full proposed set of 65 measures would be too burdensome for newly formed accountable care organizations. IHA recommends a set of 32 of the measures be adopted for the first year, which starts in 2012. It also recommends dropping six measures altogether, primarily for reasons of redundancy. "We are also concerned that a number of the proposed measures have yet to be fully specified for ACO-level measurement, which means that they have not all been sufficiently tested or validated for their intended purpose," according to the comment letter.

Other recommendations include:

* Provide more specifics on when an ACO's performance will be audited and reduce the administrative burden by using existing auditing sources.

* Reward ACOs not only for attaining high performance scores but also for their rate of improvement. "The rationale for this recommendation is based upon our California Pay for Performance program results, which indicate that physician organizations in lower socio-economic regions have less capacity for self-reporting, begin with lower baseline performance and have fewer resources to dedicate to quality improvement activities," according to the comment letter. "Therefore, a purely 'tournament' style method of determining shared savings rewards may disadvantage those ACOs requiring the largest investment. Offering incentives which reward both improvement and attainment provides a more balanced approach."

The comment letter is available at


Register or login for access to this item and much more

All Health Data Management content is archived after seven days.

Community members receive:
  • All recent and archived articles
  • Conference offers and updates
  • A full menu of enewsletter options
  • Web seminars, white papers, ebooks

Don't have an account? Register for Free Unlimited Access