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The NCQA and AMGA issue statements on accountable care organization
November 15, 2010
Health Law Alert
Author(s): Carly B. Eisenberg, Carolyn Jacoby Gabbay

The National Committee for Quality Assurance (NCQA) and the American Medical Group Association (AMGA) have each issued statements expressing their view on how to facilitate the success of existing and future accountable care organizations (ACOs), networks of providers furnishing services to a specified group of patients.  This alert discusses the standards and principles published by NCQA and AMGA.

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An accountable care organization (ACO) consists of a network of providers furnishing services to a specified group of patients. The Patient Protection and Affordable Care Act (PPACA) requires the Centers for Medicare and Medicaid Services (CMS) to promulgate regulations facilitating the creation of ACOs for Medicare enrollees by January 1, 2012. ACOs are expected to improve the administration of heath care, achieve better patient experiences and outcomes, and decrease costs by better coordinating care and monitoring quality. The National Committee for Quality Assurance (NCQA) and the American Medical Group Association (AMGA) have each issued statements expressing their view on how to facilitate the success of existing and future ACOs.

The National Committee for Quality Assurance is a non-profit organization with the mission of improving the quality of health care. The NCQA seeks to accomplish this goal by developing quality standards and performance measures for a variety of health care entities. The NCQA is seeking comments on its recently released “ACO Draft 2011 Criteria,”[1]  which it believes will help to “assess the core capabilities that increase the probability of ACO success.” The criteria are broken down into different “standards,” each having individual elements that are scored. The standards are:

  • The organization clearly defines its organizational and leadership structure.
  • The organization has the capability to manage its resources effectively.
  • The ACO arranges for pertinent health care services and determines payment arrangements and contracting.
  • The organization ensures that it has sufficient numbers and types of practitioners who provide primary and specialty care.
  • Primary care practices within the ACO provide patient-centered care.
  • The organization collects and integrates data from various sources, including, but not limited to electronic sources for clinical and administrative purposes.
  • The organization conducts an initial assessment of new patients’ health.
  • The organization uses appropriate data to identify population health needs and implements programs as necessary.
  • The organization provides resources for, or supports, the use of patient care registries, electronic prescribing, and patient self-management.
  • The organization can facilitate timely information exchange between primary care, specialty care, and hospitals for care coordination and transitions.
  • The organization has a policy that states its commitment to treating patients in a manner that respects their rights, its expectations of patients’ responsibilities, and privacy. A method is provided to handle complaints and to maintain privacy of sensitive information.
  • The organization measures and reports clinical quality of care, patient experience, and cost.
  • At least annually, the organization measures and analyzes the areas of performance and takes action to improve effectiveness in key areas.

The American Medical Group Association is organized for the purpose of improving “health care for patients by supporting multispecialty medical groups and other organized systems of care.” In June 2010, the AMGA released its “Accountable Care Organization Principles.”[2]  The AMGA published these principles in an effort to facilitate the regulatory development of accountable care organizations fueled by PPACA. The principles are:

  • Multispecialty medical groups and other organized systems of care make the strongest foundation for ACOs.
  • ACOs must be physician-led.
  • ACOs must be willing to be held accountable for clinical results and cost efficiencies in the communities served.
  • ACO incentives must be aligned to foster voluntary participation.
  • ACOs must have a primary care core.
  • ACOs should be “learning organizations” that gather and use data to improve the efficiency and safety of patient care.

These NCQA standards and AMGA principles should be considered by health care organizations as they develop their ACO strategies in response to the health care reform movement. 

Carly Eisenberg assisted in the preparation of this alert.


  1. Available at http://www.ncqa.org/portals/0/publiccomment
    /ACO/ACO%20Criteria_Public_Comment.pdf
    .
    [Back to reference]
  2. Available at http://www.amga.org/AboutAMGA/
    ACO/principles_aco.asp
    .
    [Back to reference]

The foregoing has been prepared for the general information of clients and friends of the firm. It is not meant to provide legal advice with respect to any specific matter and should not be acted upon without professional counsel. If you have any questions or require any further information regarding these or other related matters, please contact your regular Nixon Peabody LLP representative. This material may be considered advertising under certain rules of professional conduct.