VNAA Submits Comments to CMS on ACOs
Tuesday, March 4, 2014
by: VNAA Policy Team

Section: Quality and Educational Programming

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On Feb. 28, VNAA submitted comments to Dr. Patrick Conway, Deputy Administrator for Innovation and Quality and Chief Medical Officer at the Centers for Medicare and Medicaid Services (CMS). VNAA's comments addressed how Accountable Care Organizations (ACOs) can fully integrate home health and hospice services provided by VNAA members.

In preparing the comments, VNAA consulted with its full membership. Profiles of ACO initiatives by VNAA members in Massachusetts, Connecticut, New Hampshire and New York illustrate the leadership of VNAA members.

VNAA strongly supports expansion of ACO opportunities, especially for home health and hospice agencies, and makes the following recommendations to achieve that goal:

  1. The Department of Health and Human Services should formally recognize home health and hospice agencies as safety-net providers in ensuring access to care in underserved rural and urban areas and for low-income beneficiaries as it has done with FQHCs and RHCs.
  2. Allow home health and hospice agencies to establish and lead their own ACOs. Federal guidance should establish the inclusion of home health and hospice agencies, either at the formation of an ACO or during an ACO performance year.
  3. ACOs should receive an increased percentage of savings based on the percentage of their beneficiaries who visit a home health or hospice agency during the performance year. Shared-savings only models should receive an additional two percentage points and shared-risk-savings models should receive up to an additional five percentage points.
  4. Consider waivers of certain Medicare regulations to facilitate inclusion of home health and hospice agencies in ACOs.
  5. Provide funding and incentives to home health and hospice agencies to participate in ACOs to facilitate the use of health information technology. In addition, CMS should consider paying for certain services not allowable under the current Medicare benefit such as an initial assessment visit.
  6. The Center for Medicare & Medicaid Innovation (CMMI) should provide additional funding to address issues related to interoperability of health information systems in ACO models.
  7. Quarterly performance reports should break out individual organization performance accurately so that participants in an ACO are able to monitor progress.
  8. CMMI should provide additional guidance and templates for data use agreements to fast track adoption by ACOs. These templates could then be used by ACOs meet the needs of their individual organization.
  9. Conduct a study on clinical risk adjustment with input from stakeholders, to address both clinical and socio-economic factors not previously considered in ACO models. Consider factors identified by VNAA's study on vulnerable patients.
  10. CMMI should sponsor national meetings and educational conference calls that foster exchange of "lessons learned" and "best practices" across different ACOs and demonstration models. Programs should include targeted discussions on the unique role of home health and hospice.
  11. CMMI should convene a meeting of stakeholders currently participating in multiple ACOs or other CMMI payment reform demonstrations to provide input on problems and solutions related to healthcare delivery and distribution of shared savings.

Read the full letter here.


VNAA supports CMMI in its efforts to demonstrate new models of care through ACOs and other payment demonstrations. However, VNAA strongly urges CMMI build upon the findings of its November 2013 Evaluation report that highlight the importance of post-acute care. Home health and hospice care provides great value by reducing the need for care in institutional settings and avoids hospitalizations. This value holds true for both post-acute and community admitted patients.

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