Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017 #00013 

Submission Number:
00013 
Commenter:
Jeff Squier
Organization:
NEWHVN
State:
Wisconsin
Initiative Name:
Proposed Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program, FTC Matter No: V100017
Suggested Revisions:1. New No-Risk Track 1 alternative2. 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 team3. Simplify Regulatory Demands?Expedite/simplify application process?Simplify reporting requirements?Don?t require board restructuring4.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