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
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.