Cross David, Temple, TX

Document ID: CMS-2010-0259-0428
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: April 07 2011, at 12:00 AM Eastern Daylight Time
Date Posted: April 11 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: April 7 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: June 6 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c1e8bd
View Document:

This is comment on Proposed Rule

Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations (CMS-1345-P)

View Comment

My concern, after 22+ years dealing with the military cost / payment system, is that if an ACO comes in well under the cost benchmark, that benchmark is set lower and lower annually, so as eventually to be unattainable, and even unsustainable. Benchmarks must remain realistic, and not rebenchmarked to the individual organization's accomplishments the prior year. There is always a point beyond which further savings are unattainable.