The Secretary of the Department of Health and Human Services (HHS) has made available a participation waiver of federal fraud and abuse laws in connection with the operation of accountable care organizations (ACOs) that have entered into a participation agreement under the Medicare Shared Savings Program (MSSP) with the Centers for Medicare & Medicaid Services (CMS).
The Mary Washington Health Alliance (ACO) Governing Body has duly authorized the arrangements below and made a bona fide determination that each arrangement is reasonably related to the purposes of the MSSP because the arrangements will promote accountability for the quality, cost and overall care for Medicare beneficiaries assigned to ACO. The descriptions of relevant arrangements are set forth below for the purpose of ACO availing itself of the protections afforded under the MSSP Waivers:
- ACO has implemented a care coordination arrangement beginning January 1, 2016, pursuant to which the ACO identifies certain Medicare beneficiaries as being at high risk or rising risk and actively engages such beneficiaries under a navigation program constituting an evidenced-based approach to improving patient engagement and improving the overall efficiency of care.
- ACO has entered into a Hospital Quality and Efficiency Program with Mary Washington Hospital, of the ACO’s providers/suppliers as of January 1, 2016, for purposes of the implementation by the ACO of quality initiatives that will support the efficiency and efficacy of various transitions of care processes in a manner that is transparent to patients, has detailed quality controls and implements safeguards to ensure compliance with applicable laws. Specifically, the ACO Governing Body has made a bona fide determination that the program promotes accountability for the quality and cost of overall care for Medicare beneficiaries assigned to the ACO.
The ACO has approved the Surgical Advanced Practitioner Arrangement (the “Arrangement”) which will begin on or about September 1, 2016. Under the Arrangement, the ACO will employ a full-time qualified, experienced, and appropriately licensed allied health professional (e.g., a nurse practitioner or physician assistant) (“Allied Health Professional”) who will be located at Mary Washington Hospital (“MWH”) or Stafford Hospital (“SH”) for the purpose of assisting physician-participants of the ACO with respect to surgical procedures performed in MWH and SH. Such duties shall be assigned by the ACO, and may evolve from time to time, but shall include clinical and administrative activities designed to optimize the coordination among and engagement of health care team members and the patient in promotion of the ACO’s quality and cost objectives.
The Arrangement is designed to promote MWHA’s population health management capabilities, improve management and coordination of patient care for Medicare beneficiaries to encompass the hospital setting, and represents a key investment in MWHA’s infrastructure and redesigned care processes to achieve high quality and efficient service delivery for patients, including Medicare beneficiaries. This Arrangement will be located at MWH and SH for the purpose of assisting physician-participants of MWHA with respect to surgical procedures performed in MWH and SH. Specifically, the ACO Governing Body has made a bona fide determination that the program promotes accountability for the quality and cost of overall care for Medicare beneficiaries assigned to the ACO.