National criteria for Accountable Care Organizations (ACOs) was released by the National Committee for Quality Assurance (NCQA) several weeks ago.  Their draft Qualifying criteria are a set of core capabilities that an ACO should demonstrate to be recognized as an accountable entity.  Organizations would meet these criteria at the outset and be reviewed against them at intervals of every 2 to 3 years.  NCQA is seeking comments on 2011 Draft Accountable Care Organizations (ACO) Criteria.  Reviewers are asked to submit their comments in writing via the public comment Web site by 5:00 p.m. (EST) on Friday, November 19, 2010.  Here is the link to their site:  http://www.ncqa.org/tabid/1266/Default.aspx.

While submitting comments, NCQA is encouraging responders to provide thoughts and insight on the following issues related to the ACO criteria:

• For each individual standard and element, please provide feedback on whether you believe it reflects a core capability that all ACOs should possess.
• Should the types of specialists that should be included in the ACO be specified in the criteria?  If so, must they be part of the organization's legal structure (i.e., subject to the direct authority of the ACOs governance)?
• We are proposing four levels of scoring for ACOs.  What capabilities would you expect to see for each ACO level?
• Does the eligibility criteria capture the organization types that have the capability to act as ACOs (i.e., provide the full continuum of services, coordinate care, manage resources effectively, report performance)?  Should additional arrangements or structures be considered?
• How might currently available measures such as HEDIS, Meaningful Use, and California IHA (listed in Appendix A) be used?  Do the criteria align with stakeholder expectations for ACOs?  Are there gaps or areas not addressed but should be?
• For organizations seeking to become ACOs:  Does your organization have materials/documents, etc. to demonstrate compliance with the criteria?  If not, which areas are challenging?
• Are there critical functions not included in the current draft standards?

Clearly some of these criteria insight categories provide long-term care entities an opportunity to suggest criteria that there be a plan for interoperable records to include the SNF, and that transitions include LTC partners.  The Association is working with the American Health Care Association on the submission of comments prior to deadline.

Patti Cullen, CAE
952.851.2487
pcullen@careproviders.org

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