This policy brief from Geiger Gibson/RCHN Community Health Foundation Research Collaborative at the George Washington University School of Public Health examines the Centers for Medicare and Medicaid  (CMS) proposed rule for Medicare Shared Savings Accountable Care Organizations (ACOs) for its impact on safety net providers such as community health centers and Medicare beneficiaries in medically underserved communities.

The proposed rule allows federally qualified health centers (FQHCs) and Rural Health Centers (RHCs) to participate in Medicare ACOs, but their Medicare beneficiaries would NOT be included in the calculation of participating beneficiaries because of CMS’s interpretation that beneficiaries assigned to a Medicare ACO must be provided health care services directly by a physician and current systems for FQHC billing data does not identify the actual provider of care for each encounter.

The analysis does note that the proposed rule attempts to create two incentives to include FQHCs and RHCs in the Medicare ACOs by exempting them from certain risk adjustments and allowing an additional 2.5 percent in shared savings available for the Track One, one-sided risk model and an additional 5 percent in shared savings available for the Track Two, two-sided risk model.  However, the analysis points out that since the FQHC or RHC own Medicare beneficiaries are not assigned or counted as part of the ACO, these incentives would be meaningful only if a significant number of Medicare beneficiaries in an ACO obtained services at the FQHC or RHC when they are not their primary health care provider.  [This actually runs counter to one of the core assumptions of the ACO model, to support primary care medical homes that would improve coordination of care.  And it is not clear how any savings would be attributable or appropriately shared with any participating FQHCs.]

This issue of how safety net providers such as FQHCs and RHCs will or will not be able to participate in Medicare ACOs will be one of the vital policy issues to be resolved as the regulations are finalized before the Medicare Shared Savings ACOs begin to implemented January 1, 2012.

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