Lisa Remington’s Series on Accountable Care Organizations: Part II

The Remington Report‘s Lisa Remington has provided this article special to HCAF that details Accountable Care Organizations, established in the Patient Protection and Affordable Care Act of 2010. This article is part one in a series. For more information about ACOs and other trends impacting the home care industry, consider joining Remington’s Executive Academy on Health Care Reform.

Part II – ACOs And Medicare Beneficiaries: What Changes For Post-Acute Services?

By Lisa Remington, Publisher, The Remington Report

The ACO interim rule  provided information about the enrollment of Medicare beneficiaries into an ACO. Only Medicare fee-for-service beneficiaries can be assigned. Beneficiaries still have choices about whether to participate or not.

Strategically for post-acute services providers, there isn’t a cookie cutter approach to ACOs. Strategic initiatives for Medicare beneficiaries will address: Medicare Advantage plans, population health management, non-ACO Medicare beneficiaries, and participation with new payment reform models. ACOs are another model of health care. Not all hospitals and physician groups will elect to participate in one. The key to any of these models is clinical integration. More on that in a moment.

Five Key Points About ACOs And Medicare Beneficiaries

  1. Enrollee population: To participate in the Medicare Shared Savings Program, a proposed ACO must apply to CMS and agree to provide higher quality and lower cost care to at least 5,000 Medicare beneficiaries for a period of three years. Only Medicare fee-for service beneficiaries will be assigned to ACOs. [Note: for scalability, it is likely ACOs will need to manage at least 20,000 Medicare lives.]
  2. Medicare enrollee notification: Providers must notify beneficiaries of their participation in an ACO. Beneficiaries may then choose to receive services from that provider or seek care from another provider that is not part of the ACO. Providers must notify beneficiaries that they may share their Medicare claims data with the ACO and give beneficiaries the opportunity to opt-out of the data-sharing arrangements.
  3. Beneficiaries will not be assigned to more than one ACO.
  4. Beneficiaries will not receive advance notice of their ACO assignment. However, providers participating in ACOs will be required to post signs in their facilities indicating their participation in the program and to make available standardized written information to Medicare fee-for-service beneficiaries whom they serve. Additionally, all Medicare patients treated by participating providers must receive a standardized written notice of the provider’s participation in the program and a data use opt-out form.
  5. Only Medicare fee-for service beneficiaries will be assigned to ACOs.

What Does This Mean For Post-Acute Services?

The most prominent role for post-acute services is aligning clinical integration with an ACO. For the most part, the structure (eg: physician owned, governance, etc), is a formality of the structure of the ACO itself. Clinical integration is achieving collaboration with providers across care settings.  The government has given us enough information to begin today to achieve clinical integration through their release of such things as value-based purchasing plans, data on readmissions, never events, etc. Post-acute services should not be delaying their critical participation. This message again gets  reiterated through understanding that about 11% of the Medicare population will participate in ACOs. The focus for post-acute services and ACOs heightens when we start talking about payment reform such as global payments, shared savings, episodic payments. In the meantime, there is a big opportunity to align with providers across care settings and to help them understand home care services.

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