Q: During the public comments period there were these two sort of opposing forces, one being patient-centric organizations, notably the Campaign for Better Care, which maintained the ACO bar had to be high enough to effect change, and the other being associations such as AMGA, AHA, CHIME, which said the rules and associated expenses were prohibitively stringent. Do the final rules close that gap?

A: I’m hoping. We believe that the bar should be set right, so that it is not attainable by anyone who wants to participate without doing something, but not so high as to discourage participation by those who might be able to contribute something. The main promise of the ACO model over time is to turn the very fragmented system into one that is more integrated. And that will produce not only benefits for the Medicare program but I’m hoping for greater care quality delivered and for societal benefits. I have to take my white hat off now, but it’s true. We really do believe and that’s why we were so enthusiastic when this thing was put into law and so deeply disappointed when the proposed framework was issued. This appears, at first blush, to be better.

Q: The final rule is more realistically achievable, so it’s not a huge leap to think that more ACOs will emerge because of that.

Q: CMS administrator Donald Berwick said during the announcement that the final rule makes a stronger ACO framework. But does making it easier to qualify as an ACO really strengthen that framework?

A: I’m not sure that qualifying is all that much easier. Look, we’ve got to do something. Many healthcare policy folks agree the current system is unsustainable. Fragmented, un-coordinated care is a large contributor to the state of affairs now. There are many others, as well. This thing has great promise; we want that promise to be realized.