The Robert Wood Johnson Foundation, which for decades has funded initiatives to improve the accessibility and quality of care across the nation, has provided comments to federal officials on the proposed rule to establish a Medicare Shared Savings Program for accountable care organizations.

The foundation, with extensive experience in mentoring new approaches in health care, recommends a series of changes to build trust among health professionals who take the voluntary steps to participate in the Shared Savings Program. These changes include:

* Eliminate a provision that enables an ACO to drop health care professionals, but not permit the ACO to add health professionals. "That prohibition and resulting one-way professional turn-over, arguably, hurts rather than helps address America's many health care workforce challenges," according to the comment letter.

* Eliminate a provision that enables the Centers for Medicare and Medicaid Services to change the rules during the shared savings period. "In this ACO voluntary effort, entities will be exposed to new financial risk. The final rule should give pioneering ACO efforts comfort that the rules will not suddenly change."

* Under the proposed rule there is a significant risk that an ACO will fail, but these ACOs would be excluded from trying again in the future. "CMS clearly has a strong rationale for ensuring an ACO that has caused real harm to patients or whose health professionals have acted in nefarious ways should not be eligible for a subsequent attempt," the foundation's letter notes. "On the other hand, this effort to establish ACOs is new, voluntary and with many unknown aspects and features. Perhaps, a more flexible approach in the final rule that fosters voluntary participation rather than penalizing well-meaning, otherwise acceptable initiators who might have had understandable difficulties might be appropriate."

Full text of the Robert Wood Johnson Foundation's letter is available here.


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