MMS Comments on Medicare ACO Regulations

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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