Comment on the Centers for Medicare and Medicaid Services (CMS) Request for Information Regarding Accountable

. . 601 New Jersey Avenue, N.W. • Suite 9000 . . . Washington, DC 20001 . . . 202-220-3700 • Fax: 202-220-3759 . . . . www.medpac.gov . . . . . . Glenn M. Hackbarth, J.D., Chairman . . . Robert A. Berenson, M.D., F.A.C.P., Vice Chairman . . . Mark E. Miller, Ph.D., Executive Director November 22, 2010 Dr. Donald M. Berwick Administrator Centers for Medicare & Medicaid Services 200 Independence Avenue, SW Suite 314-G Washington, DC 20201 RE: File code CMS-1345-NC Dear Dr. Berwick: The Medicare Payment Advisory Commission (MedPAC) welcomes the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) Request for Information Regarding Accountable Care Organizations and the Medicare Shared Savings Program, published in the Federal Register, vol. 75, no. 221, pages 70165 to 70166. Your request regards certain aspects of polices and standards that will apply to accountable care organizations (ACOs) participating in the Medicare program under section 3021 or 3022 of the Patient Protection and Affordable Care Act (PPACA). If structured carefully, a shared savings program for ACOs could present an opportunity to correct some of the undesirable incentives inherent in fee-for-service payment and reward providers who are doing their part to control costs and improve quality. It could do so most effectively by having those providers share risk with Medicare for cost growth for their patients. ...