2. Chris Van Gorder, CEO of Scripps Health:
"Probably our biggest concern is the patient assignment process. The initial [proposed] regulations required primary care physicians to be exclusive to an ACO. Now, based upon many complaints, CMS appears to have eased that regulation significantly. It appears now that physicians can participate in multiple ACOs by using different Tax Identification Numbers (billing under their own or the different ACO TINS).
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"I think this will just confuse the issue of patient attribution to the ACOs. I can understand the desire on the part of physicians to work with multiple organizations, but if the goal is to establish an integrated, patient-friendly, high-quality, medical management system, I can't see that happening effectively if the patient and physician is moving in and out of that system.
"And, it will be very difficult to manage the economics of such a system. Fortunately, I don't think many physicians will want to practice that way and so my hope is that this concern does not become a significant issue down the road."
3. Dan Mendelson, CEO of Avalere Health, a healthcare advisory firm based in Washington, D.C.:
"The new rule is an easier pill to swallow, but still difficult for most systems to fully digest. ACOs will get to keep more of the upside profits from effective cost control – including savings from reduced re-hospitalizations – and there are fewer quality metrics and many of the industry's legal concerns appear to have been addressed. But fundamentally, most health systems continue to struggle with the fact that their present operations are oriented toward billing per service, and not taking on risk and responsibility for quality."