To:       NHPCO Members
From:   NHPCO Regulatory Team
Re:       June 09, 2011

NHPCO Comments on Proposed Accountable Care Organization Rules

NHPCO submitted a comment letter to CMS on the proposed Accountable Care Organization (ACO) Rules on Monday, June 6.   The comments included several key points:

1. The ACO Proposed Rule did not include a single reference to hospice or end-of-life care.  NHPCO gave references for the cost savings generated by the use of hospice services and referenced the high cost of end of life care.
2. ACOs should have the option of including hospices as an ACO participant or partner.
3. NHPCO urged CMS to require ACOs to include specialists in their leadership and management structure who have experience and expertise in hospice and palliative care.
4. NHPCO commented that ACOs should be required to describe how they will address beneficiary needs across the entire continuum of care, including post-acute services and end-of-life care needs. Hospice and palliative care providers are an important part of the continuum of care, and should be considered core components of the ACO model.
5. NHPCO urged CMS to require that this include systems to provide information about, and promote the use of, advance care planning.
6. NHPCO noted that there are no quality measures in the proposed rule specifically related to end-of-life care.  Palliative/end-of-life measures and the CMS hospice measures, when approved, should be part of the list of proposed measures to assess the quality of care furnished by an ACO.
7. NHPCO commented that there are measures included in the proposed rule which would not be appropriate for terminally ill patients, such as measures for routine preventive care, and that hospice patients should have an opt-out provision.

Read NHPCO’s comment letter (PDF).  Additionally, look for an article about ACOs in the July 2011 issue of NewsLine.

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