MN

Document ID: CMS-2010-0259-0002
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: November 18 2010, at 12:00 AM Eastern Standard Time
Date Posted: November 30 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: November 17 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: December 3 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b97f07
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There is not much to say about ACOs except that they are mini-HMOs intended to act as cost control gatekeepers following the failure of HMO corporation gatekeepers to control costs. ACOs, therefore, have all the pitfalls of managed care: · Transferring underwriting risk from huge and powerful "payers" (HMO/MCO corporations and government agencies) to small relatively powerless incorporated "providers" cannot change the basic problem that managed care gatekeeping has not worked for decades to control inflation. · Clinicians have no control from the bedside over political tax subsidies that drive demand inflation or over poverty, cultural status, and managed care regulations (price-fixing, networks, etc.) that drive diminished population quality statistics, therefore, pay contingent on controlling either costs or quality at the bedside are futile. · "Quality" statistics are a facade to hide the transfer to clinics of the "payers" financial conflict of interest with patients. The creation of clinician double agents plying the dual roles of caregiver and insurance underwriter in a white coat are a serious danger to the patients, public, and the professional delivery of medical care. Cost control requires changing the tax code subsidies favoring the appearance of cheap insurance driving demand inflation.

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