June 12, 2020


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Caravan Health has submitted a comment letter on the latest CMS interim rule making changes to accountable care organizations and Medicare telehealth. The interim rule published last month expands Medicare telehealth, offers ACOs relief from COVID costs and performance losses during the public health emergency, and allows ACOs to continue in the same risk track for 2021, among other changes.

While most of these changes are welcome, CMS needs to go further to safeguard ACOs during this public health emergency.

ACOs are a valuable asset for the Medicare program, especially during this time of extreme stress on our health care system, and should be protected. Many of the changes to telehealth and virtual care will make it easier to patients to access care without a risk of infection to themselves or their care providers. These rules make it clear that many more providers can deliver a wide range of services to vulnerable populations, however some items need to be expanded or clarified.

Overall, these changes do not go far enough to prevent this public health crisis from exacerbating a health care delivery crisis.

We recommend completely disregarding ACO quality and performance data in 2020, implementing a new incentive system for COVID-19 related activities, and several other changes that will allow ACOs to pull through this public health emergency stronger than ever. 

Read our comment letter here.

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