June 3, 2011 - WASHINGTON - The American Medical Association (AMA) today submitted comments to the Centers for Medicare and Medicaid Services (CMS) on their proposed rule on Medicare Accountable Care Organizations (ACOs). The AMA supports developing and testing ACOs as one of an array of payment and delivery innovations, but it has urged CMS to make significant changes to the proposed rule to allow all interested physicians to lead and participate.

"A well-developed ACO model has the potential to improve care coordination and quality while promoting cost savings, and to help ensure success the AMA has asked CMS to make numerous revisions and to issue an interim final rule that allows the flexibility to adapt as needed," said AMA President Cecil B. Wilson, M.D.

The AMA offered constructive changes to the proposed payment and risk structure of ACOs to encourage participation by physicians in all practice sizes, including providing a payment option that does not require shared loss and allowing groups to receive a percentage of all savings achieved.

"Forming an ACO requires significant resources for a physician practice, and CMS must allow those who take this risk to fully share in the benefits from day one," said Dr. Wilson.

The AMA also made several recommendations to CMS on changes related to patient interaction, including assigning patients to ACOs based on voluntary agreements, and allowing physicians to know which patients are in their ACO.  

"Patients are critical to the success of these new delivery models, and ACOs should only include patients who are interested in participating, with information to help them receive the full benefits," said Dr. Wilson.

The AMA urged CMS to revise the requirements placed on ACOs, including reducing the mandatory percentage of primary care physicians who must be using electronic health records by the second year. The AMA also recommended changes to quality measures and reporting requirements, including allowing ACOs to report on a lower number of quality measures most relevant to their patient population and ensuring that the information used to calculate the quality measures is updated and transparent.

The AMA submitted comments last week to the FTC and DOJ regarding their proposed policy on ACOs.