Lucas-Roberts Duane, Walla Walla Clinic, WA

1) If an RHC is ineligible to participate directly as an ACO, then how do the RHC primary care patients and their expenditures get factored into an ACO that is being encouraged (2.5% enhancement) to add RHCs as ACO participants, i.e how are the RHC's patient costs factored into the target expenditure benchmark and actual ACO peformance when CMS is excluding RHCs from being ACOs because CMS cannot track our costs in the same way it does FFS providers? 2) The regs tout the cost-effectiveness of RHCs. We have 5,000 Medicare patients using our RHC for their primary care. We would like the option of bringing those 5,000 patients into our own ACO and being credited for the cost-effective and quality care we know we are providing. Why can't CMS figure out a methodology to make that happen?