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12/17/2015

The Unavoidable Interaction Between ACOs and CMS's Recently Announced Hip & Knee Replacement Bundled Payment Demonstration (December)

If you are interested in how CMS resolved, or not, the interaction between the ACO program and the agency's recently finalized CJR (Comprehensive Care for Joint Replacement) demonstration the trade publication, Accountable Care News recently published my essay, "Missed Opportunity: CMS Fails to Address the Interaction Between the CRJ Demo and the ACO Program." This is a truly in-the-weeds issue since both the ACO program and CJR demo operate under very complicated and detailed regulations amounting to well over 500 Federal Register pages.  Here, I'll just note my conclusion.

"CMS believes the CJR demo will operate in isolation or "alongside" the ACO program having no spillover effects. The agency just simply needs to (literally) account for financial overlap when the CJR and ACO beneficiary are one in the same. This is the same silo-ed thinking the agency used in creating the BPCI. In the ecology of Medicare program however CMS can never do one thing. Providers in the demo and the ACO program interact and this interaction will be competitive if not antagonistic. What ACO providers generally will see is a flawed solution to a contrived problem. They'll see a demo that will either increase utilization and/or reduce their ability to earn shared savings. Had CMS thought synthetically or cast the CJR demo to complement the ACO program, the agency could have likely tempered over utilization, improved shared decision making and care coordination and moved a reluctant ACO provider community to gradually accept downside financial. Instead, the Medicare program, as a program, will be left compromised."

  

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