Deadline Passes for Comments on Accountable Care Organizations

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Healthcare Experts HCSpecialists are Among the Many Groups Seeking to Influence the Proposed Medicare Regulations - Along with Doctors, Hospitals, Insurers & Health Plans

Medicare risks having ACOs provide inadequate care for seniors, while missing a major opportunity to reduce costs.

In a public comment submitted to the Centers for Medicare & Medicaid Services, experienced health experts Human Capital Specialists call attention to the lack of behavioral health integration within the proposed regulations that will create Accountable Care Organizations (ACOs). A key feature of healthcare reform, ACOs intend to establish an innovative delivery system for Medicare services. The potential benefit of the ACO model has already facilitated new business partnerships between insurers, hospitals and physicians.

“The proposed ACO regulations are in direct conflict with recent national policy on mental health and substance abuse treatment,” says Dr. Greg Greenwood, founder and president/CEO of HCSpecialists. “Unless these rules are modified prior to adoption, Medicare risks having ACOs provide inadequate care for seniors while missing a major opportunity to expand the use of effective treatments and reduce costs.”

HCSpecialists collaborates with health plans, insurers, providers and public health leaders to optimize healthcare resources and improve patient outcomes. HCSpecialists’ approach is theoretically grounded in a “total health” view: Health is not simply the result of biological causes, but is a complex interplay of medical, psychological and sociological factors.

HCSpecialists’ public comment on the proposed ACO regulations explains how the rules contradict federal and state legislation, and undermine advancements in sponsored healthcare programming. Three changes to the regulations are recommended:

1. The definition of “ACO Professional” should include clinical psychologists.
The law governing Medicare currently recognizes that physicians cannot be the exclusive supervisors of care. Inclusion of psychologists is critical to the success of ACOs because mental health conditions – especially undiagnosed and untreated depression - are prevalent among Medicare beneficiaries.

2. The rules’ proposed “patient-centeredness criteria” should include behavioral health.
The ACO regulations contain standards for improved care through increased patient engagement. But the proposed rules require treatment that is based on medical disorders and presentations only. This fails to acknowledge the psychological and social factors that impact patients and their treatment adherence. Rather than a limited focus on pharmaceuticals, surgery or other traditional medical procedures, patients can benefit substantially from interventions that focus on behavior change and social environment.

3. Medicare would require screening for depression, but should also evaluate treatment outcomes.
Among 65 quality performance indicators, the proposed rules require ACOs to screen patients for depression. HCSpecialists recommends an enhanced guideline – one already promoted by other federal health systems -- for initiating treatment and evaluating progress.

“As proposed, the ACO regulations could have unintended negative consequences,” says Dr. Larry Cesare, a psychologist and veteran healthcare executive in Wooster, Ohio. “These rules may impact the entire healthcare system, so the focus must be on achieving the best results. Behavioral health services are a proven way to reduce medical service utilization and costs, while improving clinical effectiveness, patient satisfaction and meaningful outcomes.”

Founded in 2008, California-based HCSpecialists collaborates with healthcare leaders to provide practical patient-centered solutions that are sensitive to bottom-line business concerns. For more information about the company's services, team, and resources, visit


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