Final ACO Regulations and Guidance

I have finally finished reading the Shared Savings ACO regulations and companion guidance.  No wonder it took so long.  There are so many changes ranging from major policy changes to smaller changes intended to reduce burden.  In my career with CMS, I do not remember any final regulation where the policy moved so far from the policies outlined in the NPRM. It is clear that CMS really listened to all of the comments. I think CMS wants this program to work.  Initial feedback from stakeholders seems to be mostly positive. 

However, the devil is in the details.  While there are substantial improvements in the final rule, there are still a lot of requirements that organizations must meet to be approved for the Shared Savings program. The timetable is very tight.  We haven’t seen the application yet and even though the start dates have been extended, interested organizations need to consider the real timeline prior to the start date.  This includes strategy discussions, organizational and financial assessments, and the work necessary to develop the detail that will be required to complete an application.  Organizations interested in applying for the Advance Payment funds will need to apply for an April or July 2012 start date as well as submit two separate applications — the ACO application and an application for Advance Payments.  It will be interesting to see how many organizations want to be on the cutting edge of delivery system reform with Medicare as a partner.