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New Accountable Care Model Information From CMS


CMS has announced details on two new "accountable care organization" approaches under the Medicare program.

 -- First, the CMS Innovation Center is now accepting applications for the "Pioneer ACO Model," which will provide a faster path for mature ACOs that have already begun coordinating care for patients. Organizations interested in applying to the Pioneer ACO Model must submit a letter of intent on or before June 10, 2011. Applications must be received on or before July 18, 2011. The Pioneer ACO Request for Application, the Letter of Intent form and the Application form may be accessed at The Innovation Center will hold an Open Door Forum to review the Pioneer ACO Model Request for Application on June 7, 2011.

The Pioneer ACO Model is designed for health care organizations and providers that are already experienced in coordinating care for patients across care settings. It will allow these provider groups to move more rapidly from a shared savings payment model to a population-based payment model on a track consistent with, but separate from, the Medicare Shared Savings Program.   The government says it is designed to work in coordination with private payers by aligning provider incentives, which will improve quality and health outcomes for patients across the ACO, and achieve cost savings for Medicare, employers and patients.

The payment models being tested in the first two years of the Pioneer ACO Model are a shared savings payment policy with generally higher levels of shared savings and risk for Pioneer ACOs than levels currently proposed in the Medicare Shared Savings Program. In year three of the program, participating ACOs that have shown a specified level of savings over the first two years will be eligible to move a substantial portion of their payments to a population-based model. 

Pioneer ACOs will be expected to improve the health and experience of care for individuals, improve the health of populations, and reduce the rate of growth in health care spending. Participating ACOs will be held financially accountable for the care provided to their aligned beneficiaries. In addition, CMS will publicly report the performance of Pioneer ACOs on quality metrics, including patient experience ratings, on its website.

 -- Second, the CMS Innovation Center is seeking public comments on whether it should offer an Advance Payment Initiative that would allow certain ACOs participating in the Medicare Shared Savings Program access to a portion of their shared savings up front, helping providers make the infrastructure and staff investments crucial to successful ACOs. The advance payment would be made in the form of a monthly payment for each aligned Medicare beneficiary. Advance payments would be recouped through the ACOs' earned shared savings. ACOs would need to provide a plan for using these funds to build care coordination capabilities, and meet other organizational criteria.Public comments are sought by June 17th, 2011.

More information about the Advance Payment ACO Model can be found at: The Innovation Center will accept comments on the Advance Payment ACO Model, if submitted prior to June 17, 2011. Comments should be submitted via email to:

CMS will also be offering ACO Accelerated Development Learning Sessions to provide the executive leadership teams from existing or emerging ACO entities the opportunity to learn about essential ACO functions and ways to build capacity needed to achieve better care, better health and lower costs through integrated care models. Four sessions will be offered in 2011. Each will include a focused curriculum on core competencies for ACO development, such as improving care delivery to increase quality and reduce costs; effectively using health information technology and data resources; and building capacity to assume and manage financial risk. Additionally, the Accelerated Development Learning Sessions will not discuss elements of or specific requirements for participation in any CMS ACO program, including the Medicare Shared Savings Program.
Individuals wishing to attend the June Accelerated Development Learning Session in person may register at

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For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Arthur N. Lerner
Partner – Washington, D.C.
Phone: +1 202.624.2820

Jacinta Alves
Counsel – Washington, D.C.
Phone: +1 202.624.2573