Advanced marketing issues for ACOs

by Frank Tiedemann on February 26, 2012

Have your Medicare patients been assigned to a friendly ACO? Have your physicians joined a friendly ACO? Are your physicians encouraging their Medicare patients to authorize personal healthcare information to be reported to CMS? Is the news media helping your organization to explain the accountable care process? These and many other questions should be answered by your advanced ACO marketing plan.

The question of patient assignment continues to bedevil the rollout of Pioneer ACOs. The term assignment is confusing and misleading. Medicare enrollees do not join an ACO or even a physician’s practice which is a member of an ACO. CMS uses the term to describe its statistical analysis of Medicare costs by physician for the sole purpose of identifying which ACOs are eligible to participate in Medicare shared savings.

A Medicare enrollee is assigned to the primary care Medicare provider who bills Medicare for the largest dollar amount of covered services in a given year. As ever, each Medicare enrollees is free to seek services from any Medicare contracted provider and to freely switch providers. It’s only in the Medicare statistical evaluation that the assignment process helps CMS to identify which primary care physician generated the most legitimate clinical activity for each enrollee.

To further muddy the water, CMS requires that participating ACO physicians must inform their Medicare eligible patients of the opportunity to opt out of having personal clinical information reported to CMS for the purpose of statistical evaluation. Although the standard of clear and simple information is mandated by CMS in communicating this rule, letters to patients and messages posted in physician practices associated with a few pioneer ACOs have already set off a firestorm of confusion and media attention.

CMS requires that all ACO marketing materials be reviewed and approved in advance of their implementation. Easy to do when there are only 32 pioneers. Anticipating a time when there are hundreds, possibly thousands, of ACOs, CMS regulation also states that materials are presumed to be approved if the sponsoring organization hears nothing within 5 days of their submission for approval. Just wait for the finger-pointing when there’s a public meltdown over some communiqué sent out on the 6th day without explicit CMS approval.

Finally, there are some fascinating branding issues each organization will face in the introduction of a new ACO. How will you identify your ACO with the sponsoring organization? What language will best identify the role and purpose of your ACO? And how does the vulnerable Medicare enrollee population understand what’s happening to their preferred physicians?

I address these and other questions in my new “PlayBook for the Accountable Care Strategist”. You may download a free copy of the PlayBook at .

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