Today, the
MMS submitted 20 pages of comments on the federal
government's
proposed regulations for Medicare accountable care
organizations (ACOs). Our comments were based on the
principles for health care reform approved by the
Massachusetts Medical Society's House of Delegates last month.
Our comments include:
- Physician leadership, from both primary care and specialty care
physicians, for the implementation of new delivery system,
including ACOs.
- Medicare patients must have the freedom to choose their own
physician and ACO. The regulation proposes to assign patients based
on where they have received most of their care in the recent
past.
- The 65 proposed quality measures are excessive and flawed, and
will discourage many small practices from participating in a
Medicare ACO. We stated that it's "unnecessarily punitive" to
require that practices meet every measure to qualify for the
"shared savings" distributions at year's end, particularly since
many of the measures are hospital-based. We also believe the
measures are inadequate for practices with a large number of senior
patients.
- The proposed withhold of 25% [this may need explanation?] is
too high, and will hinder small practices from inviting in IT and
other infrastructure improvements.
Last week, in similar comments,
the American Medical Association recommended substantial
changes in the regulations. Separately, leaders of
the
Mayo Clinic, Cleveland Clinic, Geisinger Health System and
Intermountain Health criticized the rule. One official at
Mayo said, "There'd have to be substantial revisions for us to
participate."
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