Although the American Medical Group Association (AMGA) agrees with most of the draft criteria for credentialing accountable care organizations (ACOs), AMGA is concerned that creating several tiers of ACOs may dilute initial ACO efforts and limit their chances for success.
“If tiers are adopted, they should be limited to two levels: Mature ACOs, which have the infrastructure necessary to be accountable for cost and quality and Provisional ACOs, those that have substantially all of the capabilities and can reach maturity within three years,” the Alexandria, Va.-based AMGA stated in a release last week.
In addition, AMGA recommended that the National Committee for Quality Assurance (NCQA) eliminate the provision requiring ACOs to carry stop-loss insurance/reinsurance. “Such coverage primarily applies to insurance companies that assume risk, not potential ACOs, and would apply to only a handful of potential ACOs and is premature at this point in ACO development,” according to the statement.
AMGA suggested that NCQA criteria for patient rights and responsibilities comport with current federal laws and regulations in all cases. AMGA stated it “strongly supports” those standards relating to information exchange for care coordination and transitions and population health management, among others.
Despite the support for certain criteria, AMGA suggested that the 30-day comments period is insufficient and restricts the ability to develop written comments. “Sixty to ninety days for a comment period should be the norm, as should be allowing unabridged comments. None of our comments is to be construed as an endorsement of the NCQA criteria by AMGA,” the organization wrote.
Finally, the NCQA's draft criteria are premature in the absence of federal rules, according to AMGA. “Given the nature and origins of ACOs as a Medicare initiative, federal regulations should be taken into account prior to the creation of such criteria. The nature and scope of specialty care in an ACO should not be set forth in the criteria. In federal requirements, only primary care capability is stipulated, and that in broad-brush terms,” the statement concluded.
To view the complete content of AMGA's comments to NCQA, click here.