Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017 #00006 

Submission Number:
00006 
Commenter:
C ABRAHAM
State:
Texas
Initiative Name:
Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017

THE PROPOSED ENTIRE "ACO-ACCOUNTABLE CARE ORGANISATION" RULE IS A WASTE OF PUBLIC MONEY/TAX DOLLARS AND SHOULD BE SCRAPPED-IT IS THE SAME AS THE OLD "HMO-HEALTH MAINTENENCE ORGANISATION" MODEL FROM DECADES AGO WHICH COMPLETELY FAILED THE AMERICAN PUBLIC-THE WORST CARE CAME WITH COMBINATIONS OF HOSPITALS WITH DOCTORS AS EMPLOYEES AND HENCE SUBJECT TO HEALTH CARE RESTRICTIONS WHICH ARE NOT IN THE BEST INTEREST OF THE PATIENT. A.REASONS WHY THE ACO IS BAD 1.THE DOCTOR-PATIENT RELATIONSHIP IS DESTROYED - MEDICAL DECISIONS WILL BE MADE BY THE ACO ORGANISATION TO TRY TO LIMIT EXPENDITURES 2.SAME MODELS FAILED IN CANADA / UK/ FRANCE / ETC - DO WE REALLY NEED TO REPEAT THE MISTAKES THEY MADE ? 3.EACH PATIENT IS UNIQUE - IT IS NOT LIKE MAKING CARS OR TVS IN A FACTORY - THE ACO MODEL WILL LIMIT PROVIDERS TO BEING EMPLOYEES AND HAVING TO FOLLOW A SET 'CARE PROTOCOL' TO LIMIT EXPENDITURES - THIS IS NOT IN THE BEST INTEREST OF THE PATIENT. 4.NO ONE CAN DISPUTE THAT NO WHERE ELSE IN THE WORLD EXCEPT HERE IN THE USA CAN ONE WALK INTO A PHYSICIANS OFFICE AND THEN PROCEED WITH A TREATMENT PLAN DECIDED DIRECTLY BETWEEN THE PATIENT AND DOCTOR WITHOUT OUTSIDE INTERFERENCE - SUCH AS HIP SURGERY OR HERNIA SURGERY AS SOON AS MEDICALLY POSSIBLE- USUALLY IN DAYS - LOOK AT OTHER COUNTRIES WITH THE ACO TYPE HEALTHCARE AND THERE ARE UN-NECESSARY DELAYS DUE TO THE ACO HAVING TO APPROVE THE PLAN AND THEN FURTHER WAITING TIME TO GET THE ACTUAL PROCEDURE - LEADS TO MONTHS OF WAITING OUTSIDE IN CANADA AND UK AND OTHER COUNTRIES 5.AGAIN SINCE EACH PATIENT IS UNIQUE AND UNPREDICTABLE - IT IS RIDICULOUS TO EXPECT THAT IF THE DOCTORS TREAT EACH PATIENT FOR THE BEST POSSIBLE OUTCOME THAT THE SAME DOCTORS WILL THEN HAVE TO PAY OUT OF THIER OWN POCKETS BACK TO THE GOVERNMENT IF THE TOTAL EXPENDITURE ON THE PATIENTS ASSIGNED TO THAT ACO EXCEEDS WHAT WAS ALLOTED TO THAT ACO !!! - THIS IS WHAT IS PROPOSED IN THE ACO RULES!!! THERE CAN ALWAYS BE MULTIPLE PATIENTS THAT WILL END UP IN THE ICU WHERE EXPENDITURES ARE HIGH - THEN IN AN ACO THE HOSPITAL WILL TRY TO PRESSURE THEIR EMPLOYED DOCTORS TO MOVE PATIENTS TO CHEAPER FLOORS QUICKER - AGAIN EXAMPLE OF OUTSIDE INTERFERENCE IN THE DOCTOR-PATIENT RELATIONSHIP B. WHAT SHOULD INSTEAD BE DONE BY OUR US GOVERNMENT: 1.RESPECT THE DOCTOR-PATIENT RELATIONSHIP - DONT TRY TO PUT ANYTHING BETWEEN THAT WHETHER IT IS CALLED ACO OR HMO - THE RESULT IS JUST RATIONED CARE FOR ECONOMICS - THERE CANNOT BE ANY ECONOMIC LIMITS APPLIED WHEN THE DOCTOR WANTS ONLY THE BEST CARE FOR EACH AND EVERY PATIENT. 2.ENACT REAL FEDERAL TORT REFORM SUCH AS PASSED IN TEXAS - WHICH HENCE HAS NO SHORTAGE OF PHYSICIANS 3.WAKE UP AND ADMIT THAT THE CURRENT SOCIAL SECURITY AND MEDICARE SCHEMES ARE ACTUALLY GIGANTIC PONZI SCHEMES RUN BY THE GOVERNMENT - THERE IS LESSER COMING IN THAN GOING OUT AND THIS WILL RUNOUT IN THE NEXT DECADE OR SO - INSTEAD THERE NEEDS TO BE A FLAT TAX THAT EVRYONE PAYS - WHY SHOULD THE WHOLE OF GE CORPORATION PAY NO TAX IN 2010 - THE RICH AND WELL CONNECTED ARE ABLE TO EMPLOY ENOUGH LAWYERS/ACOOUNTANTS SO THEY PAY NO TAX - WITH A FLAT TAX THERE ARE NO LOOPHOLES AND EVERYONE WILL PAY INTO THE POT WITHOUT EXCEPTIONS OR EXEMPTIONS 3.SUPPORT COUNTY HOSPITALS EVERYWHERE - ANY ONE WITHOUT INSURANCE OR INABILITY TO PAY SHOULD BE ALLOWED TO WALK IN AND CAN GET EXCELLENT CARE AT THESE CENTERS WHICH ARE USUALLY STAFFED BY MEDICAL COLLEGE PROFESSORS - EXAMPLE COOK COUNTY HOSPITAL IN CHICAGO 4.TAKE LOBBYISTS OUT OF WASHINGTON - CURRENTLY MASSIVE AMOUNTS OF MONEY IS SPENT ON RE-ELECTION POTS WITH OBVIOUS EXPECTATIONS FROM THE CONTRIBUTORS - THE HOSPITAL LOBBY AND THE PHARMACY LOBBY ARE OBVIOUSLY ACTIVE TO PROTECT THEIR INTERESTS WITH MASSIVE AMOUNTS OF MONEY - HOWEVER THE ORDINARY DOCTOR IS BUSY IN HIS PRACTICE TAKING CARE OT THE PATIENT IN THE ICU AND THE CLINIC AND CHECKING LABS AND ANSWERING PHONE CALLS - THE GOVERNMENTS RESPONSIBILITY IS TO STANDUP FOR THE CITIZENS - THE PATIENT AND THE DOCTOR - NOT TO LISTEN TO VARIOUS LOBBIES