The Essential Correlation Between Capital Formation and the Building Of Value Metrics in ACOs

Robert James Cimasi, Todd A. Zigrang

Abstract


As the U.S. healthcare delivery system continues to evolve from a volume-driven payment system toward an outcome-centered, value-based reimbursement system, developing a sustainable financial model is vital and will necessitate complex, detailed analyses of the challenges and opportunities involved in supporting the investment in a new accountable care organization (ACO). Since the passage of the Affordable Care Act (ACA) in 2010, the number of emerging healthcare organizations, such as ACOs, which have developed to address this shift to value-based purchasing, has grown from 41 to over 600.  Healthcare decision makers seeking to establish an ACO are well served by first developing a financial plan that will afford the organization adequate capital funding necessary for both the ACO’s initial capital investment and for working capital to finance ongoing operations until the new ACO generates sufficient revenues to become self-sustaining. 

This paper provides an overview of the capital concepts related to the investment categories pertinent to the development of ACOs, as well as, the decision-making process involved in attracting, structuring, allocating, and budgeting the requisite capital. It also presents the concept of value metrics with a discussion of cash flows and feasibility analysis, and the various analytical methods related to determining the financial feasibility of, and value in, developing an ACO. The paper concludes with a brief synopsis of relevant regulatory considerations involved in ACO capital formation that should be addressed in the development, implementation, and operation of an ACO, e.g., Anti-kickback Statute, False Claims Act, Stark Law, Fraud and Abuse, Antitrust, and Tax Exempt Status.


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“Early Adopters of the Accountable Care Model: A Field Report on Improvements in Health Care Delivery,” By Sharon Silow-Carroll & Jennifer N. Edwards, The Commonwealth Fund (2013), p. 16; “Team –Based Care at Mayo Clinic: A Model for ACOs,” By Leonard L. Berry & Dan Beckham, Journal Healthcare Management Volume 59 (2014), p. 9, 12.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 8.

“National ACO Survey: Conducted November 2013,” National Association of ACOs (2014), p. 8.

“National ACO Survey: Conducted November 2013,” National Association of ACOs (2014), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 2.

“Early Adopters of the Accountable Care Model: A Field Report on Improvements in Health Care Delivery,” By Sharon Silow-Carroll & Jennifer N. Edwards, The Commonwealth Fund (2013), p. 16; “Team –Based Care at Mayo Clinic: A Model for ACOs,” By Leonard L. Berry & Dan Beckham, Journal Healthcare Management Volume 59 (2014), p. 10.

“Early Adopters of the Accountable Care Model: A Field Report on Improvements in Health Care Delivery,” By Sharon Silow-Carroll & Jennifer N. Edwards, The Commonwealth Fund (2013), p. 16; “Team –Based Care at Mayo Clinic: A Model for ACOs,” By Leonard L. Berry & Dan Beckham, Journal Healthcare Management Volume 59 (2014), p. 10.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 1, 16.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 2.

Sharon Silow-Carroll & Jennifer N. Edwards, Early Adopters of the Accountable Care Model: A Field Report on Improvements in Health Care Delivery, The Commonwealth Fund, 16 (2013).

Sharon Silow-Carroll & Jennifer N. Edwards, Early Adopters of the Accountable Care Model: A Field Report on Improvements in Health Care Delivery, The Commonwealth Fund, 16 (2013).

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 2.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 4.

“Getting Ready for Accountable Care Organizations,” By Joseph Goedert, Health Data Management (Apr. 1, 2011), http://www.healthdatamanagement.com/issues/19_4/getting-ready-for-accountable-care-organizations-42230-1.html?zkPrintable=1&nopagination=1.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 10.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 2.

“The Work Ahead: Activities and Costs to Develop an Accountable Care Organization,” American Hospital Association (2011), p. 2.

“Medicare Shared Savings Program: Accountable Care Organizations,” Federal Register, Vol. 76, Issue 19528 (Apr. 7, 2011), p. 67891.

“The Handbook of Financing Growth” By Kenneth H. Marks, et al., John Wiley & Sons, Inc., 2009, p. 22-23.

“Capital Structure Strategy in Health Care Systems,” By John R.C. Wheeler, et al., Journal of Health Care Finance, Vol. 26, Issue 4 (2000), p. 43.

“Capital Structure Strategy in Health Care Systems,” By John R.C. Wheeler, et al., Journal of Health Care Finance, Vol. 26, Issue 4 (2000), p. 4, 47.

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson Cost of Capital: 2011 Yearbook,” Morningstar, Section 8 (2013).The date in Column A changes from December to March in 2011 and beyond after Morningstar discontinued the production and support of its Valuation Resources product line, which the data as of December of each year until 2011 references. For the subsequent years, the information was retrieved from another Morningstar product, the annually updated book Ibbotson Cost of Capital.

“Ibbotson SBBI: 2012 Valuation Yearbook - Median data for SIC code 806: Hospitals 2001-2011,” Morningstar, http://ccrc.morningstar.com/IndSearch.aspx# (Accessed 4/25/12); “Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“Ibbotson Cost of Capital: 2012 Yearbook,” Morningstar, Section 8 (2012).

“Ibbotson Cost of Capital: 2013 Yearbook,” Morningstar, Section 8 (2013).

“2014 Valuation Handbook: Industry Cost of Capital,” Chicago, IL: Duff & Phelps (2014), Section 806.

“8 Strategies for Hospital Borrowers in 2011,” By James W. Blake, et al., Healthcare Financial Management, Vol. 65, Issue 4 (2011), p. 74.

“Financial Management in Health Care Organizations,” By Robert A. McLean, Delmar Publishers (2003), p. 192.

“An Examination of Contemporary Financing Practices and the Global Financial Crisis on Nonprofit Multi-Hospital Health Systems,” By Louis J. Stewart and Pamela C. Smith, Journal of Health Care Finance Vol. 37, Issue 3 (2011), p. 3.

“An Examination of Contemporary Financing Practices and the Global Financial Crisis on Nonprofit Multi-Hospital Health Systems,” By Louis J. Stewart and Pamela C. Smith, Journal of Health Care Finance Vol. 37, Issue 3 (2011), p. 3, 5.

“Patterns of Financing for the Largest Hospital Systems in the United States,” By William O. Cleverley & Jane Baserman, Journal of Healthcare Management, Vo. 50, Issue 6 (2005), p. 362.

“Methodology for Determining Shared Savings and Losses under the Medicare Shared Savings Program,” Department of Health and Human Services, Nov. 2012, 5, http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/sharedsavingsprogram/Downloads/ACO_Methodology_Factsheet_ICN907405.pdf (Accessed 2/12/14); “Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72844-72845.

“National Health Expenditure Projections 2013-2023” Center for Medicare & Medicaid Services, September 17, 2014, http://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/NationalHealthExpendData/NationalHealthAccountsProjected.html (Accessed 11/19/2014), Table 17; “Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72807-72808, 72844-72845.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72844-72845.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72845.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72844-72845.

Minimum cost reduction resulting in shared savings calculated as the result of the Benchmark (see Exhibit 7, Line 3) multiplied by the MSR (see Exhibit 7, Lines 6, 9, and 12).

Maximum cost reduction resulting in shared savings calculated as the result of the Total Savings Payment Cap (see Exhibit 8) divided by the appropriate Quality Sharing Rate: up to 50% for Track 1 ACOs, up to 60% for Track 2 ACOs, and up to 75% for Track 3 ACOs. In order to earn the maximum Quality Sharing Rate for a given Track, the ACO must achieve a sufficiently high score on various quality metrics, as discussed above.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72845.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72845.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72808.

“Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72807-72808, 72844-72845.

Minimum cost overage resulting in shared losses calculated as the result of the Benchmark (see Exhibit 7, Line 3) multiplied by the Minimum Loss Rate (MLR) (see Exhibit 7, Lines 6, 9, and 12).

Maximum cost overage resulting in shared losses calculated as the result of the Loss Sharing Limit divided by the appropriate Shared Loss Rate.

Loss Sharing Limit is calculated as a percentage of the ACO’s benchmark: (1) 5% of the benchmark for Track 2 ACOs in PY 1; (2) 7.5% of the benchmark for Track 2 ACOs in PY 2; (3) 10% of the benchmark for Track 2 ACOs in PY 3 and any subsequent PYs; (4) 15% of the benchmark for Track 3 ACOs (does not vary with PY).

Shared Loss Rate follows the methodology for the Quality Sharing Rate, excluding Track 1 ACOs, which are not at risk for losses: up to 60% for Track 2 ACOs, and up to 75% for Track 3 ACOs. The maximum cost overages calculated above assume the maximum Shared Loss Rate.

“Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235, p. 72781.

“Press Release: Medicare’s Delivery System Reform Initiatives Achieve Significant Savings and Quality Improvements – Off to a Strong Start,” The Centers for Medicare & Medicaid Services, Jan. 30, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2014-Press-releases-items/2014-01-30.html (Accessed 4/17/14).

“Press Release: Medicare’s Delivery System Reform Initiatives Achieve Significant Savings and Quality Improvements – Off to a Strong Start,” The Centers for Medicare & Medicaid Services, Jan. 30, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2014-Press-releases-items/2014-01-30.html (Accessed 4/17/14).

“Essentials of Managerial Finance,” By J. Fred Weston & Eugene F. Brigham, The Dryden Press: 9th ed. (1990), p. 564.

“Dictionary Of Health Economics and Finance,” By David Edward Marcinko & Hope Rachel Hetico, Springer Publishing Company (2007), p. 359.

“Corporate Finance,” By Stephen A. Ross, et al., Canada, McGraw-Hill Ryers: 4th Canadian ed. (2005), p. 942.

“National ACO Survey: Conducted November 2013” National Association of ACOs, January 21, 2014, https://www.naacos.com/pdf/ACOSurveyFinal012114.pdf (Accessed 5/7/2015), p. 2.

“National ACO Survey: Conducted November 2013” National Association of ACOs, January 21, 2014, https://www.naacos.com/pdf/ACOSurveyFinal012114.pdf (Accessed 5/7/2015), p. 2.

“The Dictionary of Health Economics,” By Anthony J. Culyer, Edward Elgar Publishing Limited: 2nd ed. (2010), p. 347.

“Capital Planning for Clinical Integrations,” Daniel M. Grauman et al., Healthcare Financial Management Association, Vol. 65 (2011), p. 4-5.

“Dictionary of Health Insurance and Managed Care,” By David Marcinko, Springer Publishing Group (2006), p. 161.

“National Health Expenditure Projections 2013-2023” Center for Medicare & Medicaid Services, September 17, 2014, http://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/NationalHealthExpendData/NationalHealthAccountsProjected.html (Accessed 11/19/2014), Table 17; “National ACO Survey: Conducted November 2013” National Association of ACOs, January 21, 2014, https://www.naacos.com/pdf/ACOSurveyFinal012114.pdf (Accessed 5/7/2015), p. 2; “Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations; Proposed Rule” Federal Register Vol. 79, No. 235 (December 8, 2014), p. 72844-72845, 72870.

“Next Generation ACO Model” Centers for Medicare & Medicaid Services, http://innovation.cms.gov/initiatives/Next-Generation-ACO-Model/ (Accessed 3/18/2015).

“Next Generation ACO Model: Model Overview Presentation” Centers for Medicare & Medicaid Services, March 17, 2015, http://innovation.cms.gov/Files/slides/nextgenaco-odf1slides.pdf (Accessed 3/20/2015), p. 14.

“Next Generation ACO Model: Request for Applications” Centers for Medicare & Medicaid Services, http://innovation.cms.gov/Files/x/nextgenacorfa.pdf (Accessed 3/20/2015), p. 32.

“Next Generation ACO Model: Request for Applications” Centers for Medicare & Medicaid Services, http://innovation.cms.gov/Files/x/nextgenacorfa.pdf (Accessed 3/20/2015), p. 13.

“Next Generation ACO Model: Request for Applications” Centers for Medicare & Medicaid Services, http://innovation.cms.gov/Files/x/nextgenacorfa.pdf (Accessed 3/20/2015), p. 18.

“Accountable Care Organizations: What Providers Need to Know” Centers for Medicare & Medicaid Services, April 2014, http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/sharedsavingsprogram/Downloads/ACO_Providers_Factsheet_ICN907406.pdf (Accessed 5/15/2015), p. 3.

“Next Generation ACO Model: Request for Applications” Centers for Medicare & Medicaid Services, http://innovation.cms.gov/Files/x/nextgenacorfa.pdf (Accessed 3/20/2015), p. 14-16.

“Next Generation ACO Model: Request for Applications” Centers for Medicare & Medicaid Services, http://innovation.cms.gov/Files/x/nextgenacorfa.pdf (Accessed 3/20/2015), p. 12.

“National Health Expenditure Projections 2013-2023” Center for Medicare & Medicaid Services, September 17, 2014, http://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/NationalHealthExpendData/NationalHealthAccountsProjected.html (Accessed 11/19/2014), Table 17; “Next Generation ACO Model: Request for Applications” Centers for Medicare & Medicaid Services, 2015, http://innovation.cms.gov/Files/x/nextgenacorfa.pdf (Accessed 5/7/2015), p. 18, 36; “National ACO Survey: Conducted November 2013” National Association of ACOs, January 21, 2014, https://www.naacos.com/pdf/ACOSurveyFinal012114.pdf (Accessed 5/7/2015), p. 2.

“Health Care Economics,” By Paul J. Feldstein, Thomson Delmar Learning: 6th ed. (2005), p. 424.

ROBERT JAMES CIMASI, ACCOUNTABLE CARE ORGANIZATIONS: VALUE METRICS AND CAPITAL FORMATION, 213 (Taylor & Francis 2013).

“A Decade of Health Care Cost Growth Has Wiped Out Real Income Gains For an Average US Family,” By David I. Auerbach and Arthur L. Kellermann, Health Affairs, Vol. 30, No. 9 (2011), p. 1634.

Note that: (1) five federal ACOs did not report quality data; and, (2) the results from Performance Year 2 has not yet been reported for MSSP ACOs. “Medicare’s delivery system reform initiatives achieve significant savings and quality improvements - off to a strong start,” Centers for Medicare & Medicaid Services, Jan. 30, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2014-Press-releases-items/2014-01-30.html (Accessed 3/10/15); “Fact sheets: Medicare ACOs continue to succeed in improving care, lowering cost growth”, Centers for Medicare & Medicaid Services, Nov. 7, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2014-Fact-sheets-items/2014-11-10.html (Accessed 3/10/15).

“Medicare’s delivery system reform initiatives achieve significant savings and quality improvements - off to a strong start,” Centers for Medicare & Medicaid Services, Jan. 30, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2014-Press-releases-items/2014-01-30.html (Accessed 3/10/15).

“Medicare’s delivery system reform initiatives achieve significant savings and quality improvements - off to a strong start,” Centers for Medicare & Medicaid Services, Jan. 30, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2014-Press-releases-items/2014-01-30.html (Accessed 3/10/15).

“Lower Costs, Better Care: Reforming our Health Care Delivery System,” Centers for Medicare & Medicaid Services, Press Release, Feb. 28, 2013, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-Sheets/2013-Fact-Sheets-Items/2013-02-28.html (Accessed 3/10/15).

“Fact sheets: Medicare ACOs continue to succeed in improving care, lowering cost growth”, Centers for Medicare & Medicaid Services, Nov. 7, 2014, http://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2014-Fact-sheets-items/2014-11-10.html (Accessed 3/10/15).

“Medicare Shared Savings Program: Accountable Care Organizations,” Federal Register Vol. 76 No. 212 (Nov. 2, 2011), p. 67976 (to be codified at 42 CFR pt. 425).

“From Acquisition to Integration: Transforming a Hospital Into an ACO,” By John T. Fink and Sean Hartzel, Healthcare Financial Management Association, Oct. 1, 2014, http://www.hfma.org/Content.aspx?id=2767 (Accessed 3/10/15).

“Accountable Care Organizations: Value Metrics and Capital Formation,” Robert James Cimasi, MHA, ASA, FRICS, AVA, CM&AA, Boca Raton, FL: Taylor & Francis (2013), p. 220.

“Referral and Consultation Communication Between Primary Care and Specialist Physicians: Finding Common Ground,” By Ann O'Malley and James Reschovsky, Archives of Internal Medicine, Vol. 171, No. 1 (2011), p. 64.

“A Novel Approach to Determining Best Medical Practices: Looking at the Evidence,” By John Tucker, Houston Journal of Health Law & Policy, Vol. 10 (2010), p. 147.

“Collaborative Accountable Care: CIGNA’s Approach to Accountable Care Organizations,” CIGNA, 2011, http://newsroom.cigna.com/images/9022/media_gallery/knowledge_center/CollaborativeCare_WhitePaper_2011.pdf (Accessed 11/22/11).

“Medicare Program; Final Waivers in Connection with the Shared Savings Program; Interim Final Rule” Federal Register Vol. 76, No. 212 (Nov. 2, 2011), p. 67992; “Medicare Program; Final Waivers in Connection with the Shared Savings Program; Continuation of Effectiveness and Extension of Timeline for Publication of Final Rule” Federal Register Vol. 79, No. 201 (Oct. 17, 2014), p. 62356.

“Medicare Program; Final Waivers in Connection with the Shared Savings Program; Interim Final Rule” Federal Register Vol. 76, No. 212 (Nov. 2, 2011), p. 68000-01.

“Medicare Program; Final Waivers in Connection with the Shared Savings Program; Interim Final Rule” Federal Register Vol. 76, No. 212 (Nov. 2, 2011), p. 68000-01.

“Medicare Program; Final Waivers in Connection with the Shared Savings Program; Interim Final Rule” 76 Fed. Reg. 67992 (11/2/2011), p. 68008.

“But do you really NEED it? How your state’s Certificate of Need policy compares,” Matthew Morrill, The Advisory Board Company http://www.advisory.com/Research/Service-Line-Strategy-Advisor/The-Pipeline/2013/But-do-you-really-need-it (Accessed 3/3/14).

“UnitedHealth Group, Quarterly Report” (Form10-Q) (Nov. 7, 2013), p. 25; “UnitedHealthcare Makes $50 Billion Wager on Accountable Care As Obamacare Looms,” By Bruce Jaspen, Forbes, Jul. 10, 2013, http://www.forbes.com/sites/brucejapsen/2013/07/10/unitedhealthcare-makes-50-billion-wager-on-accountable-care-as-obamacare-looms/.

Department of Health and Human Services Secretary Kathleen Sebelius announced that 123 new Medicare ACOs had been formed, extending access to about 1.5 million Medicare beneficiaries. “More partnerships between doctors and hospitals strengthen coordinated care for Medicare beneficiaries, Centers for Medicare & Medicaid Services, Press Release (Dec. 23, 2013), http://www.hhs.gov/news/press/2013pres/12/20131223a.html (Accessed 1/9/14); “Accountable Care Growth in 2014: A Look Ahead,” By David Muhlestein, Health Affairs, January 29, 2014, http://healthaffairs.org/blog/2014/01/29/accountable-care-growth-in-2014-a-look-ahead/ (Accessed 4/17/14).

“More partnerships between doctors and hospitals strengthen coordinated care for Medicare beneficiaries,” Centers for Medicare & Medicaid Services, Press Release (Dec. 23, 2013), http://www.hhs.gov/news/press/2013pres/12/20131223a.html (Accessed 1/9/14).

“Current Trends in the Healthcare Supply Chain,” Premier, Inc., Economic Outlook (Fall 2013), p. 19; “Unlocking the Hidden Value of Healthier Communities,” Premier, Inc., Economic Outlook (Fall 2013), p. 37.

“Unlocking the Hidden Value of Healthier Communities,” Premier Inc., Economic Outlook (Fall 2013), p. 34.

As of June 20, 2013, there were 202 physician-led ACOs and 189 hospital ACOs. “A look at physician-led ACOs: What's driving them, and where they're headed,” By Beth Thomas Hertz, Medical Economics, Jun. 10, 2013, http://medicaleconomics.modernmedicine.com/medical-economics/news/look-physician-led-acos-whats-driving-them-and-where-theyre-headed.

“Accountable Care Growth in 2014: A Look Ahead,” David Muhlestein, Health Affairs Blog, January 29, 2014, http://healthaffairs.org/blog/2014/01/29/accountable-care-growth-in-2014-a-look-ahead/ (Accessed 4/22/14).

At the end of 2013, there were 260 physician-led ACOs (43%), 238 hospital-led ACOs (39%), 55 insurer-led ACOs (9%), and 53 ACOs led by other organizations, e.g. non-profit community organizations and practice management companies (9%). “Accountable Care Growth in 2014: A Look Ahead,” By David Muhlestein, Health Affairs Blog, January 2014, http://healthaffairs.org/blog/2014/01/29/accountable-care-growth-in-2014-a-look-ahead/ (Accessed 4/22/14).

“Early Adopters of the Accountable Care Model: A Field Report on Improvements in Health Care Delivery,” By Sharon Silow-Carroll & Jennifer N. Edwards, The Commonwealth Fund (2013), p. 9.


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