A ray of hope seems to lie in a proposed extension of the PGP demonstration project—at least for 10 physician groups that are petitioning CMS to revive the program for two years. Perhaps if the extension is granted, other practices will be allowed to use it as a tool to prepare for ACOs. The program would be modified to more closely align incentives for quality care and cost control to that used for ACOs.
The ACO rules are not yet final, of course. My guess is that the government wants to fill in lots of the gaps through the public comment period, which ends June 6. (Incidentally, I'll start the over/under line on total pages at 858 when final regs are released.)
If, however, some of the risk rules aren't modified, it will be clear that the government intends to start ACOs with a relatively small group of superstar organizations.
The initial regs were careful to note that CMS would likely not approve all applicants to the program. But if they want robust participation, maybe the folks at CMS should schedule a phone call with Aric Sharp or someone like him. I know he'd be happy to give them a few suggestions.