REQUIRED PUBLIC DISCLOSURE FOR THE ACO PRE-PARTICIPATION WAIVER OF BRIDGES HEALTH PARTNERS ACO LLC D/B/A BRIDGES HEALTH PARTNERS ACCOUNTABLE CARE ORGANIZATION
The Secretary of the U.S. Department of Health and Human Services has made available waivers of certain federal laws to Accountable Care Organizations participating in the Medicare Shared Savings Program (“MSSP”). To avail itself of the Pre-participation Waiver, Bridges Health Partners ACO LLC d/b/a Bridges Health Partners Accountable Care Organization (“the ACO”) has made a good faith determination that these arrangements are reasonably related to the purposes of the MSSP, has undertaken these arrangement with the good faith intention of developing an ACO that will participate in the MSSP, and is publicly disclosing such arrangements in accordance with the requirements of the MSSP.
ACO Start-Up Costs
Bridges Health Partners LLC (“Bridges”), the sole member of Bridges ACO, and certain health systems participating in the ACO, have been responsible for the organization and formation of the ACO and have incurred various start-up costs necessary for the development of the organizational structure of the ACO and submission of the application to participate in the MSSP. These start-up costs include use of Bridges internal staff and other resources, consulting services, recruitment and contracting of ACO participants and providers, and legal services, which will not be fully recovered from the ACO Participants.
ACO Distribution Plan
Pursuant to the participation agreements between the ACO and the ACO Participants, in exchange for participation in the ACO and for compliance with the various commitments required of ACO participants to undertake and operate in a manner consistent with the requirements of the MSSP, the ACO has developed a distribution plan regarding the allocation and distribution of shared savings and losses. Pursuant to the distribution plan, shared losses incurred by the ACO shall be borne by the health system ACO Participants that have been responsible for the development of the ACO, which include Butler Health System, Excela Health System, St. Clair Hospital, and Washington Health System.
APP Transitions Program
Beginning January 2018, the ACO intends to deploy advanced practice providers (“APPs”), including certified registered nurse practitioners and physician assistants employed by various ACO Participants into hospitals and skilled-nursing facilities within the ACO network to provide care coordination services to patients of the ACO Participants (the “APP Transitions Program”). During transitions of care and in certain settings, an APP caring for an ACO member may be expected to maintain care and continuity of the care plan for the member. The ACO Medical Director or an on-call designee will support APPs caring for patients should the need arise for that additional support. The use of these APPs is intended to develop a more efficient discharge process, manage and improve transitions of care at the hospital and with SNFs, and reduce patient readmissions, with an ultimate goal of enhancing the quality, efficacy, safety, and cost of services provided to Medicare beneficiaries.
Electronic Medical Record Support Program
This program supported by Bridges Health Partners ACO will advance the purposes of the Medicare Shared Savings Program by promoting greater access and accountability for the quality, cost, and overall medical care for the populations served by the ACO. The efforts of this program are directed at facilitating a consolidation of sources where a Medicare beneficiary’s care plan might be documented. Through ACO participants providing and sharing EMR technologies with each other, replacement of antiquated and incompatible technologies will occur. This support provided by a health system ACO participant to a member of its medical staff will result in alignment of data and care documentation that will support the ACO’s goal of improved clinical integration amongst its participants.