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Pioneer ACOs: Moving Toward Needed Transformation In Health Care

Debra Ness, President, National Partnership

Cross-posted from Health Affairs Blog

We have commended the Centers for Medicare and Medicaid Services (CMS) on this blog in the past for actions regarding Accountable Care Organizations (ACOs) – but we’ve also noted the need to establish strong enough criteria to ensure that this new model will be implemented in ways that deliver on the promise of better coordinated, more patient-centered care that gives us improved value for our health care dollars. 

That is why we applaud the launch of the Pioneer ACO program by the Center for Medicare and Medicaid Innovation (CMMI).  It exemplifies the kind of innovation and testing we need to forge a path out of the current dysfunctional system.

William Kramer, Executive Director for National Health Policy, PBGH

Certainly, the nation has few higher priorities than to leave behind a health system that often fails to coordinate patient care, bringing poor clinical outcomes, miserable patient experiences, duplication, waste, errors and skyrocketing costs. The financial security of families and the economic viability of our nation depend on replacing the current payment system, which rewards volume of services regardless of whether those services are appropriate or beneficial to patients.

We need a fundamental transformation, and Pioneer ACOs have the potential to significantly change the way providers coordinate, collaborate and share accountability for the patients they serve.   But the true test of whether these ACOs deliver on their promise will lie in both the spirit and specifics of how they are implemented.

The Pioneer ACOs improve upon the Medicare Shared Savings Program announced in October in a number of ways that can more quickly advance the transformation we need:

  • It has stronger financial incentives – e.g., a higher level of shared savings and risk that can move us more quickly away from fee-for-service to population-based payment to strengthen accountability for both quality and cost.
  • Requirements for the meaningful use of electronic health records (EHRs) by the majority of the ACO’s primary care providers will spur more rapid adoption of EHRs which, in turn, should facilitate care coordination across providers and settings, help clinicians improve patient outcomes, and enable patients to engage more actively in their care.
  • It encourages public-private alignment.  We agree with the CMMI that ACOs will be more successful if the participating providers see this as their core business strategy rather than as a siloed experiment limited to a select group of patients.  The requirement for Pioneer ACOs to enter similar contracts with other payers (such as commercial insurers, employer health plans and Medicaid) reinforces this.  It is important, however, that CMS not allow the “good faith effort” exception to be used to avoid this alignment.
  • The emphasis on prospective identification of ACO patients, where feasible, will enhance providers’ ability to track, assess and improve the care they deliver to patients in their ACO panels.

As important as these requirements is the strong emphasis on patient-centered criteria and accountability to a meaningful set of quality metrics that include patient experience of care.  The assessment of patient experience is essential to determining whether ACOs ultimately deliver better care and outcomes from the patient perspective.

Furthermore, the inclusion of both a patient representative and a consumer advocate on the ACO governing board is critical to ensuring that ACOs are dedicated to serving the needs of their communities and putting patients first as they redesign the care delivery process.  We cannot truly achieve a patient-centered system unless we involve patients and consumers in the governance and design process—right from the start.  Patients have a unique perspective that comes from being the only person at the interface of all facets of their care.  They are the best judges of whether the care they get is well coordinated, meets their needs and enables them to maximize their health.

Experienced consumer advocates can be key allies in ensuring that ACOs are serving and improving the health of all segments of a community.  They can also facilitate consumer education and engagement in this new model of care.

It’s too soon to predict the impact of ACOs, and there is also a need to remain vigilant—especially with respect to the potential for Pioneer ACOs to increase the market concentration of existing large health systems and to use their market power to raise prices or engage in anti-competitive conduct.

But there is cause for encouragement.  We think the Pioneer ACOs will be on the right track to realize the promise of better care and better value for our health care dollars.  If that proves to be right, our nation will be much better off.

Welcome Progress, But the Final Verdict on ACOs Is Yet to Come

Debra Ness, Leader, Campaign for Better Care

Last week, the Centers for Medicare and Medicaid Services (CMS) may have done what once seemed impossible. Its final rule on Accountable Care Organizations (ACOs) seems to have put an end to the rancor and bitter debate on this particular issue, shaping a framework that just about all parties can accept.

By responding thoughtfully to comments on the proposed rule, and balancing competing interests, the agency has given us a welcome respite from the pitched battles that are raging over so many aspects of health reform. But the real measure of success will be whether successful ACOs are soon in place, providing better-coordinated, more patient-centered care for millions of patients and giving us all a way to get better value for our health care dollars.

William Kramer, Executive Director for National Health Policy, PBGH

We believe last week’s announcement will encourage more providers to participate in this program. From the perspective of consumers, we applaud the strong emphasis on patient-centered criteria that should pave the road to better care. And especially as advocates for our oldest, sickest and highest risk patients, we applaud this

effort to incentivize better primary care, increased coordination, and shared accountability across providers. From the perspective of purchasers, we believe that CMS has crafted a foundation to hold providers accountable for quality performance and cost savings, and created a path to move providers away from today’s perverse fee-for-service system.

We are very pleased that this final rule will require ACOs to use beneficiary experience of care and outcome measures to evaluate performance. We believe CMS landed in a better place with respect to the quality measures ACOs must report on. While we appreciated the comprehensiveness of the original list of 65 measures, there were a number of measures that added minimal value. The final list of 33 measures is a stronger set that focuses on highest impact measures and, very importantly, includes measures of patient experience, functional status and clinical outcomes, care coordination and safety. We would, however, have liked pay-for-performance to occur sooner in the program, especially for measures that are already in use. Finally, we are very pleased that this final rule continues to ensure full transparency, notification and choice for beneficiaries. These provisions are all essential to engaging consumers in a positive way and realizing the promise of successful ACOs.

Nobody got everything they wanted in the final rule and we, too, have concerns. We are disappointed that the upfront anti-trust review process is no longer mandatory, but glad there is strong acknowledgement that there must be close monitoring for any signs of cost-increasing market concentration. We are glad to see that the final rule requires CMS to share ACO applications and new types of data that will strengthen the ability of the Federal Trade Commission and Department of Justice to assess and monitor the market impacts.

It is also unfortunate that the provisions requiring beneficiary participation on ACO boards have been tempered, rather than expanded to include representation from a diverse range of community stakeholders, including purchasers, labor and community-based groups. It is now incumbent on CMS to closely monitor ACOs to ensure that they reflect the community interests they are intended to serve, and that consumers, beneficiaries and other key stakeholders are engaged in the design, governance and evaluation of their performance. Consumers and purchasers hope and expect that these provisions will be strengthened down the road if needed.

Every leader from every sector has a list like this – things they like, and things they don’t like, in the final rule. But the time for tallying who won and who lost, and by how much, is over. Now it’s time for all parties to come together to create successful ACOs that deliver care that is patient-centered, that improves quality and care coordination, and that lowers costs. The stakes are too high to let anything stand in our way, or to let opponents of reform exploit any remaining differences.

We said before this rule was released that it’s time for a new dynamic where we come together to implement the reforms the nation so urgently needs. ACOs are one of many promising models and initiatives that will be tested by the CMS Innovation Center over time. It is well past time to leave our broken, dysfunctional health care system behind and give the Accountable Care Organization model the test it deserves.

The final rule gives us a chance to do that. That’s all we could ask. CMS has done its part. Now it’s time for the rest of us to do ours. If we do, patients, their families and family caregivers, our economy and our nation will benefit.

Debra L. Ness is Leader of the Campaign for Better Care and President of the National Partnership for Women & Families. William Kramer is the Executive Director for National Health Policy at the Pacific Business Group on Health. Together, they co-chair the Consumer-Purchaser Disclosure Project, a group of leading employer, consumer, and labor organizations working toward a common goal: to ensure that all Americans have access to publicly reported health care performance information.

Cross-posted from the Health Affairs Blog.