Enough time has passed for the 420-odd ACO regs to be digested. Several of the largest health systems are not happy. The Mayo clinic sent a nine-page letter to CMS (if anyone can locate the letter on the web, please post it here) indicating that their system is Triple Aim itself so Mayo is not going to participate in the program. Of course, the Oracles of Mayoland told CMS what should be done to fix the regs so they fit with what is already in place in Rochester.
The folks at Dartmouth are not worried. They expected problems with acceptance and believe the process is unfolding as it should. They are not sweating the small stuff.
The list of complaints is not "small stuff". According to the Becker's Hospital Review website, these are the problems:
Financial risk. Many providers had expected the program to offer a way for institutions to get bonuses without having to face penalties.
Quality measures. ACOs will have to collect 65 quality measures, which very few institutions now do. Adding technology and training staff to track this information could be expensive.
Financial solvency requirements. Providers joining an ACO would have to meet financial solvency requirements that could be especially hard for small practices to meet.
Governance requirements. An ACO must be a certified legal entity recognized under state law. While ACO participants must control of three-fourths of the governing body, beneficiaries must be involved in oversight.
Baseline for improvements. The baseline from which providers must improve is set at the current expenses of the provider, which doesn't reward providers who have already lowered their costs.
Member assignment. Since assignment of patients is retrospective, providers won't know for certain which beneficiaries are in their ACO until a year after the program starts.
Start date too early. Many providers believe the start date of Jan. 1, 2012 is set too early. The final rule isn't expected to be released until August, giving ACO-planners four months to meet financial requirements, set up quality metrics and enroll. However, applicants that do not meet the Jan. 1 deadline will be able to apply the following year.
Below are two article from the Congressional Quarterly