We media types, consultants and a bevy of other experts have written a lot about what it means to be an accountable care organization, but there's very little information out there about what it takes to become an accountable care organization. I'm not talking about the generalities that we are so prone to tossing around — integrated delivery, physician alignment, yada yada yada. No, I'm referencing the nuts and bolts of actually applying for and becoming an official ACO.


That's why I was so interested to tune into a webinar yesterday with Jacqueline Gisch, vice president of quality at Aurora Health Care in Wisconsin. Gisch highlighted what it takes to go through CMS' detailed review.

To be sure, Gisch and Joe Damore, vice president of engagement and delivery at the Premier healthcare alliance, which hosted the webinar, teed up the presentation with an overview of CMS' shared savings program and the changing health care landscape. First and foremost, Gisch said, you must have the triple aims built into everything you do. Organizations must also determine why they want to apply. Aurora was already toying with new delivery models that fit nicely into the ACO concept, so it was a natural progression, she said. It's also an opportunity try out new things such as paying for e-visits or enhanced home care while the industry as a whole is still stuck in a fee-for-service world.

But then Gisch spelled out exactly what ACO hopefuls can expect from the rigorous CMS review. She had some good tips:

  • Assign a single project manager for the entire process. This person should keep people on task and on deadline.
  • Communicate with key stakeholders throughout the organization, and not just doctors and the C-suite. For instance, HR needs to be engaged, she said because the ACO could impact pay and benefits.
  • Create a work plan and prepare for the process to take at least 4-6 weeks.
  • On governance and leadership, CMS is looking for very specific information about who will serve on which ACO committees and their role on the committees. She said that CMS even wanted to know each committee member's skill set and ability to influence clinical practices.
  • If your organization is an integrated delivery network, you'll need to fully explain the IDN's role in the ACO. Gisch said that CMS came back to Aurora for more details on exactly how the two organizations will mesh.
  • Be sure to detail how you'll reinvest any savings and how you intend to use data provided by CMS.
  • Importantly, tell a good story. Gisch said that CMS wanted a strong narrative on how the ACO will function and meet the triple aims. It's not enough to explain what structure you'll have in place, but also how you plan to evaluate performance and improve. And on the issue of a narrative, Gisch suggested having it reviewed by someone outside of the organization. In-house staff will write the narrative from your perspective, but it may be too inside baseball for an outsider (read: CMS) to fully understand what you are trying to accomplish. A third party can offer up constructive criticism, she said.
  • And this: talk to your IT staff before clicking that submit button. Why? Well, just four hours before their application was due, Gisch discovered that her IT system limits the size of files that can be uploaded to a portal, which is how CMS prefers to get the material. Gisch was able to electronically submit the application, but then had to overnight a disc with the supporting materials.

CMS is currently gearing up for the next round of ACO applications. Organizations must submit a notice of intent to apply by June 15. Gisch and Damore strongly suggested that any organization even thinking about going after ACO designation to this. It is non-binding, but gives CMS a heads up. Actual applications are due to the agency August 30 and would begin operations in January 2013.