Accountable Care Organizations (ACOs) June 2, 2011 Overview You’ve probably heard or read about “accountable care organizations” or ACOs: a relatively new concept that involves organizing and paying health care providers and suppliers in ways that will encourage coordinating care more efficiently, improving quality, and reducing spending, and allowing ACO providers to share in the savings they achieve.
In Section 3022 of the Affordable Care Act (P.L. 111-148) Congress required the Secretary of Health and Human Services to establish the Medicare Shared Savings Program to encourage the development of ACOs in Medicare. Congress envisioned this as a program ‘‘that promotes accountability for a patient population and coordinates items and services under parts A and B, and encourages investment in infrastructure and redesigned care processes for high quality and efficient service delivery.’’
On April 7, the Centers for Medicare and Medicaid Services (CMS) published proposed rules to implement the Medicare Shared Savings Program. Comments on these proposed rules are due by June 6.
Read the full ACO proposed rules here http://edocket.access.gpo.gov/2011/pdf/2011-7880.pdf NAPNAP's Response NAPNAP has joined with other national nurse practitioner organizations in reviewing the proposed rules and has identified a number of troubling concerns. We believe the proposed rules fall far short in acknowledging the education, clinical preparation, and current roles of nurse practitioners in designing and leading primary care practices that achieve the goals of improving patient care, enhancing quality, and lowering costs. NAPNAP submitted comments to CMS on the proposed rules on June 2, 2011. To read NAPNAP's comments, please click here. The six national organizations that make up the “NP Roundtable” have drafted joint comments responding to the April 7 proposed rule. In addition to submitting these comments to CMS for consideration, we have shared these concerns with members of Congress and other policy makers who share our interest in developing accountable care organizations that enable NPs and all health care professionals to practice to the extent of their education and ability. The comments focus on several major concerns: -
The ability of nurse practitioners to have their Medicare patients aligned with an ACO, including those established by NPs in autonomous practice. -
Recognition of the qualifications of NPs to direct the clinical management, quality assurance, and process improvement in ACOs. -
Including NPs in internal processes for measuring clinical and service performance and using the results to improve coordination of care. Click here to read the full NP Roundtable comment letter to CMS. - ANA Response to the propsed rules: The ANA has shared it’s official comments on the Centers for Medicare Services’ proposed regulations around Accountable Care Organizations. The comment letter is intended as a guide for ANA’s Constituent/State Nurses Associations and Organizational Affiliates of some of the provisions most closely affecting registered nurses and the patients they serve. Also, please be advised that May 31st, ANA submitted comments to the Federal Trade Commission and the Antitrust Division of the Department of Justice on proposed modifications of the antitrust laws to permit otherwise independent healthcare organizations to collaborate as ACOs. To better educate you on these complex yet important piece of the Affordable Care Act, we have attached two “background” documents: - “ACOs - 101” –a brief description of ACOs generally, along with links to more information available from the Centers for Medicare and Medicaid (CMS)
- “Follow the Money” – provides a more detailed description of the financial aspects of the ACO model, including opportunities and cautions for nurses.
How you can respond: If you would like to take individual action, here’s how (submission deadline is June 6, 2011) Directions for submitting comments electronically: -
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Click on the “submit a comment” tab on the home page. -
From the pull-down menu “Select Document Type” select “Proposed Rule” and check the box “Open for Comment/Submission” -
In the “Enter Keyword or ID” box, type in “shared savings” -
Click the orange “Search” box -
The first entry that appears in the list of results for “shared savings” is titled “Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations (CMS-1345-P) Comments Due Jun 6, 2011 11:59 PM ET” This is the correct document on which you wish to submit comments. -
Under the “Actions” column on the extreme right, click on “Submit a Comment” -
You will be taken to a “Submit a Comment” page. Follow the instructions for entering information, typing a 2,000-character comment in the text box, or uploading a document. -
When finished, click the “Submit” button to submit your comments. Note: Be aware that comments submitted to CMS will be made part of a public record that can be accessed by the public, the press, and other health care providers. Please keep the public nature of the comments in minds when you express your opinions. _____________________ AANP has graciously shared letter templates that NPs in own practices and NPs in physician practices may use for comments if individual NPs so desire. See below to access these sample letters.Click here to view AANP Sample template comments from NPs in own practices. Click here to view AANP Sample template comments from NPs in physician practices. AANP ACO SAMPLE LETTER Comments for Proposed Accountable Care Rule (Personal Comments for NPs in Own Practices) I am writing to comment on the proposed rule for the Medicare Primary Care Accountable Care Organizations. I would like to express my concern over the proposed barring of nurse practitioner patients from being assigned to the new Medicare Primary Care Accountable Care Organizations. This limitation will significantly impair the ability of patients to access primary care services. It will negatively affect not only access, but the cost and quality of the care provided by the ACOs. Nurse practitioners have a long history of providing high quality, cost effective care. As such they can be assets to the ACO in the areas of quality and cost savings. The required quality indicators that have been identified are within the scope of the nurse practitioner’s practice. Our skills in the area of care coordination, chronic disease management, health promotion and disease prevention will contribute significantly to the quality and cost savings of any shared saving program. I, therefore, ask that you reexamine your proposal and find a way for nurse practitioners to join ACOs as full participants, and that the patients of nurse practitioners be assigned to ACOs. (Personal Comments for NPs in Own Practices) In my practice patients have chosen me as their primary care provider and I am responsible for managing their primary care needs. Contact with a physician is based on referral and patient need. Other members of the health care team are also utilized based on patient needs. Requiring a certain percentage or even one visit by a physician each year will not work in this environment. Please rethink this proposal and utilize CMS’ or the Secretary’s power to create a more logical and inclusive system that will truly help quality and be cost effective. Sincerely AANP ACO SAMPLE LETTER Comments for Proposed Accountable Care Rule (Personal Comments for NPs in Physician Practices) I am writing to comment on the proposed rule for the Medicare Primary Care Accountable Care Organizations. I would like to express my concern over the proposed barring of nurse practitioner patients from being assigned to the new Medicare Primary Care Accountable Care Organizations. This limitation will significantly impair the ability of patients to access primary care services. It will negatively affect not only access, but the cost and quality of the care provided by the ACOs. Nurse practitioners have a long history of providing high quality, cost effective care. As such they can be assets to the ACO in the areas of quality and cost savings. The required quality indicators that have been identified are within the scope of the nurse practitioner’s practice. Our skills in the area of care coordination, chronic disease management, health promotion and disease prevention will contribute significantly to the quality and cost savings of any shared saving program.. I therefore ask that you reexamine your proposal and find a way for nurse practitioners to join ACOs as full participants, and that the patients of nurse practitioners be assigned to ACOs. (personal comments for NPs in PhysicianPractices) In my practice patients choose their primary care provider who is then responsible for managing their primary care needs. Contact with a physician is random and serves as a backup for me when I am not available. Other members of the health care team are utilized based on patient needs. Requiring a certain percentage or even one visit by a physician each year is counterproductive; it adds cost for additional visits, interferes with continuity of care and would wastes the time of the patient and physician trying to comply with the rules of the ACO. Please rethink this proposal and utilize CMS’ or the Secretary’s power to create a more logical and inclusive system that will truly help quality and be cost effective. Sincerely
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