And this from Cecil Wheeler of Maryland: "This has got to be the worst idea since junk bonds and forcing banks to make housing loans to those that just could not afford it. Stop this idiocy."
Of course the bulk of the comments came from large provider organizations that sent their multi-page comments with more formal language. Here are some of the highlights:
Premier Healthcare Alliance
A purchasing group representing some 2,500 hospitals and health systems and 75,000 healthcare sites, Premier Healthcare Alliance, had one of the longest responses, an 80-page annotated letter with charts, tables, and attachments. Throughout Premier's document, however, the bottom line was thumbs down.
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In an accompanying summary statement, Premier's senior vice president, Blair Childs wrote, "the proposed rule will discourage ACO development, which represents one of the best hopes for coordinating care in the fee-for-service (FFS) system, improving quality and reducing costs."
Echoing comments expressed by many other provider groups, Childs criticized CMS for choosing "a very prescribed approach to regulating ACOs" instead of simply developing a regulatory ceiling, above which ACO-styled operations could not go.
On the concern that CMS' retrospective assignment of patients to an ACO precludes providers from knowing which patients are in the group, Premier said CMS "should develop a set of exclusions for certain beneficiaries such as 'snow birds,' as the ACO will have no ability to affect the beneficiaries' heath and care while they are at their alternative home or traveling."
The Patient-Centered Primary Care Collaborative
Edwina Rogers, executive director of the Patient-Centered Primary Care Collaborative, a group of clinicians, insurers, consumers and businesses based in Washington, D.C., expressed a concern that CMS' intention to impose retroactive assignment of patients to an ACO after the conclusion of the performance period would create a "gaming of the system, since a group can remove the attribution of a patient" whose costs might reflect badly on their incentive payment, "by intentionally reducing billing by the physician."