Submission Number: 00013 

Received: 5/9/2011
Commenter: Jeff Squier
Organization: NEWHVN
State: Wisconsin
Agency: Federal Trade Commission
Initiative: Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program; FTC Matter No: V100017
Attachments: No Attachments
Submission Text
Suggested Revisions:

1. New No-Risk Track 1 alternative
2. New Capitated Track 3
�Range of options from global to partial, including pharmacy
�ACO owns savings or loss and would be required to reinvest a portion of their savings to benefit their patients
�Prospective assignment
�More patient engagement features such as ability to reduce member co-pay or co-insurance when they use the ACO for services
�ACO can bear upside and downside risk from day one
�No opt out of data sharing
�Organization could meet repayment and reserve requirements and Medicare Advantage-like reporting and quality requirements
�In this model of capitation, clinical decisions remain with the care team
3. Simplify Regulatory Demands
�Expedite/simplify application process
�Simplify reporting requirements
�Don�t require board restructuring
4.Put ROI in Reach
�Improve opportunity for meaningful shared savings
�Reduce costs
�Expedite shared savings distribution
�Establish low-interest revolving loan fund for organizations with limited resources
�Simplify formula for calculating shared savings so ACOs can get timely performance
5. Strengthen Attribution
�Include specialists in attribution model (especially medical specialists that provide primary care) and make them exclusive for primary care services only
�Adopt a prospective attribution model or combined prospective and retrospective to improve member engagement and focus improvements