Medicare Shared Savings Program Participation Waiver Disclosures
The Secretary of the U.S. Department of Health and Human Services has provided waivers of certain federal fraud and abuse laws that might otherwise limit innovations by ACOs participating in the Medicare Shared Savings Program ACO Model (See “Final Waivers in Connection with the Shared Savings Program” (80 Fed. Reg. 66,726 (Oct. 29, 2015))). Pursuant to the notice, Lancaster General Health Community Care Collaborative, LLC (“LGHCCC”) seeks waiver for the arrangement described below:
LGHCCC has developed a program of clinical integration (“CIP”) designed to: (i) improve the quality of and access to, and control the cost of, health care for the patients and populations served by LGHCCC’s participating providers and Lancaster General Health; (ii) improve the health of such patients and populations; (iii) monitor the health care services provided directly or indirectly through and arranged for by LGHCCC; (iv) integrate and coordinate the provision of such health care services by, and establish collaboration and accountability for such health care services by and among, participating providers; and (v) improve the patient experience for individuals receiving such health care services.
As part of the CIP, LGHCCC has entered into agreements, as recently amended, (the “Participating Provider Agreements”) with providers in LGHCCC’s community (the “ACO Participants”) for the purposes of functioning as a clinically-integrated network focused on implementing evidence-based medical practice, clinical guidelines, disease management programs and other quality improvement programs developed and implemented by LGHCCC.
The Board of Managers of LGHCCC (the “Board”) has determined that the obligations of LGHCCC and the ACO Participants, as specifically described in the amended Participating Provider Agreements, constitute an arrangement that is reasonably related the purposes of the MSSP in that the ACO Participants agree, among other commitments, to actively and meaningfully participate in the CIP, including all initiatives, efforts, and requirements related to the design, development, implementation, and operation of LGHCCC’s CIP, including, without limitation:
- Committing to accomplishing and demonstrating the triple aim of improved patient experience of care, improved health of populations, and lower per-capita cost of care;
- Actively participating in governance matters, LGHCCC committees, and workgroups;
- Encouraging investment in infrastructure and redesigned care processes for high-quality and efficient service delivery for patients, including Medicare beneficiaries, by requiring adherence to LGHCCC-adopted clinical protocols, clinical performance initiatives, measures and metrics designed to improve the quality of health care services rendered by ACO Participants.
If you have any questions and would like to contact the Lancaster General Health CCC, please call 717-544-4636 or email info@LGHealth.org.
For general information on ACOs, please contact Medicare at 800-MEDICARE (800-633-4227).