4 Accountable Care Challenges for CMS

Drawing upon our experience in helping health systems on the path to accountable care, we offer CMS these key lessons learned:

1. New Approach to Clinical Performance:  Providers must look at clinical performance differently, and Medicare's ACO policies must explicitly support fundamental care redesign.  From the perspectives of both clinical care improvement and population health management, this requires incorporation of new data sources, comprehensive decision support, and solid clinical analytics—all in a framework of continuous, data-driven, evidenced-based quality improvement.    
2. New Infrastructure for the New Value Paradigm:  The current infrastructure of health systems and other providers is based on encounters—the world of fee-for-service rates, relative value units, and quantities.  ACOs require a new kind of infrastructure that is geared toward evaluating, managing, and promoting improved clinical performance as defined and rewarded by value-based payment.
3. Strong, Multi-Payor Patient Base:  Successful ACOs will require a sufficient number of covered lives to serve.  The law requires at least 5,000 Medicare beneficiaries per ACO.  However, CMS should encourage and directly facilitate the creation of multi-payor ACOs.  While Medicare is the largest buyer of hospital and physician services, it is essential for Medicaid, private health plans, and self-insured employers to join with Medicare wherever possible.  The larger proportion of a provider's patient base covered under the ACO model, the stronger and faster will be the clinical and financial benefits for patients, providers, and payers.