Leaders of the Campaign for Better Care (CBC), a broad-based coalition of consumer organizations, said they will comment on the proposed ACO rule on Monday, commending the federal government for putting patients first.

The ACO proposed rule was issued by the Centers for Medicare and Medicaid Services (CMS) on March 31, with a comment period closing June 6.

[See also: HHS releases proposed ACO regulations.]

"The CMS Medicare Shared Savings proposed rule is moving in the right direction," said CBC officials. "The ACO proposed rule is premised on patient-centered care, patient engagement, a strong foundation of primary care, performance measurement including patient experience, and meaningful stakeholder involvement. These elements are the key to a successful ACO and genuine transformation of our
care delivery system overall."

CBC emphasized that the federal government can't afford to set the bar too low, when it comes to ACOs.

"Some are concerned about asking too much of ACOs, but we believe these new models must be held to standards that ensure they deliver on the promise of better care, better health, and lower cost," CBC leaders said. "If the bar is set too low, ACOs will likely fail – either by failing to produce real results through a fundamentally different approach to care, or by creating resistance among patients who are called on to pay for or be part of mediocre attempts at change."

CBC strongly supports the requirement that ACOs meet eight specific criteria including care coordination, patient engagement and use of patient experience to assess care and guide quality improvement.

"These features are essential for ensuring that patients achieve better outcomes," said officials. "They are also important for reducing the costs of preventable hospitalizations, medication errors, and duplicative tests and procedures."

CBC also "strongly supports" the proposal that Medicare beneficiary representatives be included on the governing board, opining that an ACO governing board should be a multi-stakeholder body that operates in the public interest and reflects the community it serves as well those providing care.

[See also: CMS announces new ACO initiatives.]

Beneficiaries and community-based consumer advocates should hold a sufficient number of seats on
the governing body to enable them to have meaningful influence on the organization and its operations, CBC leaders said. The group recommends that CMS require 50 percent of the seats on the governing body be held by beneficiaries, community-based consumer advocates and other relevant stakeholders.

CBC also supports the beneficiaries to seek care outside of an ACO. "Negative experiences with early Medicare+Choice plans are still fresh in the minds of many, and if beneficiaries believe they are being locked in to a new system without their consent they are likely to reject it out of hand – jeopardizing the potential advantages that ACOs may bring to patients and the health care system," said officials.