Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017 #00007 

Submission Number:
00007 
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

PART 2 OF MY COMMENT TITLED '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.' PART 2-(ADDITIONAL) REASONS WHY THE ACO IS BAD 6.THE ACO MODEL WILL CREATE LARGE MONOPOLIES RUN PRIMARILY BY HOSPITALS WITH THE DOCTORS AS THEIR EMPLOYEES-CURRENTLY THE COMPETETION BETWEEN HOSPITALS SERVES TO PROVIDE BETTER CARE - HOWEVER IN THE ACO MODEL THE SMALLER HOSPITALS WILL BE SHUT OUT OF THE ACO AND THERE WILL ONLY BE LEFT A FEW LARGE HOSPITALS THAT CONTROL ALL THE CASH FLOW AND THERE WILL HENCE BE LESS COMPETITION AND LESS QUALITY HENCE FOR THE CITIZENS. 7.CURRENTLY THERE ARE MULTIPLE FREE STANDING SURGERY CENTERS-THE COST OF EXAMPLE A COLONOSCOPY AT AN INDEPENDANT SURGERY CENTER IS MUCH LESS THAN THE SAME DONE AT ANY LARGE HOSPITAL-IN FACT THE GOVERMENT REWARDS THIS INEFFICIENT HOSPITAL CARE AT PRESENT BECAUSE MEDICARE PAYS MORE TO HOSPITALS TO DO THE COLONOSCOPY IN THE HOSPITAL THAN IT PAYS TO THE INDEPENDANT SURGERY CENTER FOR THE SAME QUALITY PROCEDURE AT THE INDEPENDANT SURGERY CENTER EVEN WHEN DONE BY THE SAME DOCTOR AT BOTH PLACES-THIS IS A PRIME EXAMPLE OF WHY ACOs WILL BE BAD-THEY WILL PROVIDE INEFFICIENT EXPENSIVE CARE AND THE COMPETETION WILL BE ELIMINATED BECAUSE THE MONEY IS FUNNELLED ONLY TO THE ACO UNDER THE PROPSED RULES. 8.THE ACO WILL MONOPOLISE THE HEALTHCARE IN THE ENTIRE AREA IT IS ALLOTED BY FORCING THE DOCTORS TO BECOME EMPLOYEES BECAUSE ANY DOCTOR NOT PART OF THE ACO WILL BE SHUT OUT OF THE SYSTEM-HENCE PATIENT CHOICE WILL BE LIMITED TO ONLY ACO DOCTORS 9. CURRENTLY MOST DOCTORS ARE NOT AFFILIATED WITH ANY ONE HOSPITAL AND HENCE CAN PROVIDE THE BEST CARE THEY DEEM FIT AT WHICHEVER HOSPITAL IS BEST SUITED FOR A PARTICULAR PROCEDURE OR PATIENT - IN THE ACO MODEL THIS WILL BE LIMITED BY THE MONOPOLY HOSPITAL GROUP AND HENCE THE PATIENT WILL NOT GET THE BEST HOSPITAL-THEY WILL BE RESTRICTED TO THE ACO HOSPITAL -ORIG LIST: 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