Keckley says he expects CMS will tinker with the guidelines, but he's not sure what sorts of changes might occur before the Jan. 1, 2012 implement date. "I can't imagine they will alter quality reporting. In year one its pay for reporting, not pay for performance per se. The model for the shared savings and risk, that threshold in the one-sided model that seems to be a range, they will have to be a little more explicit there," he said. "But this is A not much of a surprise to most of the folks who've been watching, so I don't think the January 1 deadlines impose major constraints unless you've convinced yourself we aren't going down the ACO path."
It's important to remember, Keckley points out, that the program is voluntary.
"I don't think that means you're not going down the physician-hospital integration path. It means you may not apply to be an ACO," he says. "If you chose that route, no harm no foul. Folks will chose other routes to physician-hospital alignment. And if you're choosing to go the ACO route this answered a lot of questions."