By: Susan Sumrell
As the discussion on the ACO proposed rules continues, we wanted to share some resources for you that will be helpful in understanding how the ACOs will work and what the proposed rules mean for health center participation in ACOs.
First, we have a summary of the health center specific provisions of the ACO proposed rules that gives you an overview of the issues we have identified and where we will be focusing our comments. Second, the George Washington University’s Geiger Gibson/RCHN Community Health Foundation Research Collaborative has put together an issue brief titled Medicare’s Accountable Care Organization Regulations: How Will Medicare Beneficiaries who Reside in Medically Underserved Communities Fare? which takes a closer look at the impact of the proposed rules on health centers and their patients.
The bottom line is that these rules, as proposed, in effect prohibit FQHCs from meaningful involvement in the development and participation in ACOs. It is critical that heath centers and PCAs become familiar with these proposed rules and submit comments to CMS regarding this shortcoming. The comment deadline for this rule is 5 p.m. on June 6, 2011.
NACHC is preparing its comments on the proposed rule and will send a draft out to health centers and PCAs two weeks before the comment deadline. We urge health centers and PCAs to read the NACHC and GWU analyses, to review the relevant provisions of the proposed rule and preamble to the rule, and to file your own comments, particularly if you have suggestions and proposals as to how CMS can revise its proposals to allow FQHCs to participate meaningfully in the ACO/shared savings program. Also, NACHC seeks any input or suggestions you may have for NACHC to include in its comments. If you have questions or suggestions regarding these proposed ACO rules, contact at NACHC: Roger Schwartz, Bruce Sturm, or Susan Sumrell.
Keep checking back for the latest info on ACOs as we develop our comments.