The Robert Wood Johnson Foundation (RWJF) provided formal comments this week to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule for the new Medicare Shared Savings Program for Accountable Care Organizations (ACO). RWJF strongly endorsed efforts to increase accountability for quality and cost in health care. Care should be accountable to patients and consumers. It should make timely, transparent data an imperative, promote health professional collaboration, support payment changes that reward high value care, improve population health and close racial, ethnic and language disparities. Based on those principles of accountability, RWJF commended CMS on efforts to increase quality, coordination and accountability in U.S. health care and offered specific recommendations to strengthen the proposed rule, including:

• Look to existing regional alliances, such as RWJF’s Aligning Forces for Quality initiative, as key partners in any delivery and payment reform for a given market.
• Identify and implement efforts to align and partner with private sector payers in building ACOs, which is important to their success.
• Leverage beneficiary choice among patients by offering and educating them about a range of quality and cost information about the care the ACO provides.
• Provide timely, transparent performance data and information that goes down to the individual health professional level.
• Expand ACO participants by allowing Federally Qualified Health Centers and Rural Health Centers to be ACOs, and for care from independent nurse practitioners at nurse-led centers to be part of the shared savings program.
• Close racial and ethnic disparities by requiring the stratification and public reporting of quality measures by patient race, ethnicity and primary language.
• Address how ACOs enhance population health and broad health determinants by requiring more specific population health assessment metrics and the utilization of local population health status data; working with patients, consumers, caregivers and other organizations in addressing multiple determinants of health; and devoting a part of the shared savings to local population health improvement activities.
• Create rules for participation that allow for adaptation over time to build trust and confidence in this new, and voluntary, approach amongst health professionals.