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ACOs: Familiarize yourself with obstacles

ACOs: Familiarize yourself with obstacles Q. What obstacles to ACO growth have been identified?

A. By January 2013, 250 Accountable Care Organizations were approved by CMS serving an estimated 4 million Medicare beneficiaries. These ACOs are located across the country with approximately 20% serving low-income and rural communities. Roughly half of all ACOs serve less than 10,000 beneficiaries. As the acceptance of ACOs increases and more receive approval, the unique hurdles become clearer. 

There are several common considerations, including a substantial financial commitment for both start-up costs and ongoing operational costs.

Start-Up Costs

� IT platform development and implementation (includes physical build-up; integration of EMR and non-EMR vendors; coordination of providers and facilities)

� Overhead, such as any business salaries, facilities, utilities, equipment, etc., which must be set up prior to operating

� Legal/regulatory costs (start-up costs, regulatory consultation and application)

� Beneficiary notification costs (notification of provider participation in ACO must be by mail/in-person at office visit using staff time and financial resources)

Ongoing Costs

� Pre-reporting exercises designed to encourage data collection skills and techniques, coordination of disease management across practice areas, and disease specific recognition programs

� Additional CMS training and communication

� Webinars for assistance during implementation, and informing providers of updated procedures and data collection.

� Expenditure benchmarks to determine savings for a particular ACO.

Carla Hogan is an attorney with Greenberg Traurig. She can be reached at 518.689.141 or


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