Medicare Accountable Care Organization (ACO)

Medicare Accountable Care Organization (ACO)

What's an ACO?

An ACO is a group of doctors, hospitals, and other health care providers, who come together voluntarily to give coordinated high quality care to the Medicare patients they serve. Coordinated care helps ensure that patients, especially the chronically ill, get the right care at the right time, with the goal of avoiding unnecessary duplication of services and preventing medical errors.

How ACOs Work

  • Local health care providers and hospitals volunteer to work together to provide you with coordinated care.
  • The doctors and other providers who are helping care for
    you will communicate with each other, and partner with you in making health care decisions.
  • You may spend less time filling out medical history paper work because your doctors may already have this information in an electronic health record.
  • You’ll likely have fewer repeated medical tests because your doctors and hospitals will share information and coordinate your care.
  • You’ll be in the center of care, and your doctors will be better able to keep you informed, and to keep listening and honoring your choices.
  • Unlike HMOs, managed care, or some insurance plans, an ACO can't tell you which health care providers to see and can't change your Medicare benefits.

How ACOs Share Information

Cleveland Clinic Medicare ACO doctors will use data from Medicare to help improve how they provide care. For example, your doctors will get your medical information from Medicare to help them to know your medical history, including your medical conditions, prescriptions, and visits to the doctor, and give you the right care at the right time in the right setting. Doctors, hospitals, and other health care providers working together in an ACO are able to read your medical records, along with other office staff authorized to help coordinate your care. The privacy and security of your medical information is protected by federal law. You'll continue to get the same rights enjoyed by all people with Medicare.

Declining to Share Your Health Information

Your privacy is very important to us, and you control how your personal information is used.
To help you get the best possible care, Medicare shares information with Cleveland Clinic Medicare ACO about the care their patients get. To prevent Medicare from sharing your personal information with Cleveland Clinic Medicare ACO:

  • Call 1.800.MEDICARE (633.4227).
  • TTY users should call 1.877.486.2048.

Consent to Change Your Personal Health Information Preference

  • Call 1.800.MEDICARE (633.4227).
  • TTY users should call 1.877.486.2048.

Cleveland Clinic Medicare ACO Contact Information

  • Call Cleveland Clinic Medicare ACO at 216.445.3666
  • Business hours are Monday – Friday 10 a.m. - 3 p.m.

Where Can I Find More Information About ACOs?

Other Resources

*Cleveland Clinic Medicare ACO is only for fee-for-service (FFS) Medicare patients and not Medicare Advantage based beneficiaries.

ACO Public Reporting Information

ACO Public Reporting Information

ACO Name and Location

Cleveland Clinic Medicare ACO, LLC
Previous Names: N/A
9500 Euclid Avenue
Mail Code: JJ19
Cleveland, Ohio 44195

ACO Primary Contact

Primary Contact Name Scott Dynda
Primary Contact Phone Number 216.445.3666
Primary Contact Email Address [email protected]
ACO Participants ACO Participant in Joint Venture (Enter Y or N)
Abrams Eye Center, INC. N
Advanced Neurology & EMG LLC N
ADVANCED WOMEN'S HEALTH AND SURGERY, LLC N
Akron General Medical Center N
Ara E. Kallibjan N
Ashtabula County Medical Center N
Associates in Orthopaedics, INC. N
ATRIUM MEDICAL GROUP, INC. N
Benhaven Counseling 2 LLC N
Broadview Heights Family Medicine, INC. N
BROWN MEDICAL CENTER, INC. N
Cardiovascular Consultants of Cleveland INC. N
CCF Tennessee Medical Services, P.C. N
Cleveland Clinic Rehabilitation Hospitals, LLC N
Cleveland Clinic Avon Hospital N
Cleveland Clinic Children's Hospital for Rehabilitation N
Cleveland Clinic Foundation Cleveland Clinic Home Care N
Cleveland Clinic Health System - East Region N
Cleveland Clinic Home Care Services N
Cleveland Clinic Support Services N
Cleveland Ear Nose Throat INC. N
CLEVELAND UROLOGY ASSOCIATES, INC N
Clinic Medical Services Company N
Community Internists INC. N
COMPREHENSIVE PRIMARY CARE N
Cosmopolitan Dermatology INC N
Cynthia Weinstein N
Dayem Health Services LLC N
DOUGLAS WEBB N
DR MIODRAG ZIVIC LLC N
DR KHALAFI, MD, LLC N
ELITE MEDICAL PRACTICE LLC N
Fairview Hospital N
FAMILY MEDICAL CARE PLUS N
FOOT AND ANKLE PHYSICIANS OF GEAUGA, INC. N
Great Lakes Hypertension & Kidney Care INC. N
Hassan Alzoubi N
Hillcrest Mayfield Eye Associates INC N
HUDSON FAMILY PRACTICE INC. N
ID CONSULTANTS OF NORTHEAST OHIO, INC. N
ID Consultants, INC N
Jeffrey A Chaitoff MD, LLC N
Jeffery A Halpert DPM, LLC N
Joel D. Weisblat, MD, INC. N
John Aron N
Katrina Rakowsky N
Key Clinics, LLC N
LAKE POINT MEDICAL GROUP LLC N
Lodi Community Hospital N
Lutheran Hospital N
MARK A. LANG, MD., LLC N
Marymount Hospital INC N
Med Consults, INC. N
Medina Hospital N
MERCY MEDICAL CENTER, INC. N
MERCY PROFESSIONAL CARE CORP N
Michael Kalus N
Mila Davidovic N
Mohan J Durve, MD INC. N
Montrose Sleep Center LLC N
N Presswala N
NEIGHBORHOOD HEALTH CARE INCORPORATED N
Nitin Govani MD PC N
Northcoast Dermatology Associates, INC. N
Northcoast Foot and Ankle Associates, INC. N
Northern Ohio Internal Medicine Associates, INC N
OBGYN of Westlake, LLC N
Ori Kushnir MD OBGYN LLC N
Oscar Nicholson JR MD INC. N
Partners Physician Group N
Prestige Foot & Ankle Center LLC N
Randal March N
Retina Associates of Cleveland, INC. N
Retina Specialists of Ohio N
Richard Koletsky N
Ronald A Freireich DPM N
RONALD GOLOVAN, MD INC.
SIGNATURE MEDS, LLC N
Signature Psychiatry Associates, INC. N
Stephen Musser DPM, INC. N
SUSHIL K JAIN MD INC
System Optics INC. N
TED PETERSON DPM N
The Cleveland Clinic Foundation N
THOMAS SLAWINSKI N
Tim Nice MD INC N
TIMOTHY LEVAR DPM LLC N
Union Physician Service LLC. N
VIJAY G MISTRY MD INC. N
Vyacheslav Isakov N
Wooster Clinic, LLC N
Yael Dinar Kushnir, MD N
Yatish Goyal MD Inc N

ACO Governing Body

Member LastName

Member FirstName

Member Title/Position

Member's Voting Power (Expressed as a percentage or number)

Membership Type

ACO Participant Legal Business Name and D/B/A, if applicable

Babiuch

Christopher

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Bertsch

John

Physician

1

ACO Participant Representative; Voting Member

New Family Physicians Associates, Inc.

Braman

Kenneth

Physician

1

ACO Participant Representative; Voting Member

Partners Physician Group

Dews

Teresa

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Gormsen

David

Physician

1

ACO Participant Representative; Voting Member

Mercy Medical Center

Henkel

Oliver

N/A

1

Medicare Beneficiary Representative and Community Stakeholder Representative; Voting Member

N/A

Hohman

Jessica

President/Medical Director/Performance Optimization Committee Chair

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Hutchison

Lew

Administration

1

Voting Member

Ashtabula County Medical Center

Johnston

Douglas

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Jones

Robert

Chair of Quality

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Jurecko

Leslie

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Lorenz

Robert

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Malloy

Mark

Finance Committee Chair

0

Non-Voting Member

The Cleveland Clinic Foundation

McMenemy

John

Physician

1

ACO Participant Representative; Voting Member

Union Physician Services

Medina

Michelle

Interim Board Chair (Interim ACO Executive)

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Rizk

Maged

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Rogen

Bruce

Physician

1

ACO Participant Representative; Voting Member

The Cleveland Clinic Foundation

Wolfe

Wes

Executive Director, MNS

1

Voting Member

The Cleveland Clinic Foundation

Key ACO clinical and administrative leadership

Interim ACO Executive Michelle Medina, MD
President & Medical Director Jessica Hohman, MD
Associate Medical Director Maged Rizk, MD
Associate Medical Director Leslie Wong, MD
Interim Chief Financial Officer & Treasurer Anthony Helton
Chief Legal Officer & Secretary David Rowan
Compliance Officer Donald Sinko, CPA
Quality Assurance/Improvement Officer Robert Jones, MD

Associated Committees and Committee Leadership:

Committee Name Committee Leader Name and Position
Executive Committee Jessica Hohman, MD, Chair
Finance Committee Mark Malloy, Chair
Performance Optimization Committee  Jessica Hohman, MD, Chair 
Compliance Committee Kenneth Braman, DO, Chair

Types of ACO participants, or combinations of participants, that formed the ACO:

  • ACO professionals in a group practice arrangement
  • Networks of individual practices of ACO professionals
  • Hospital employing ACO professionals
  • Federally Qualified Health Center (FQHC)

Shared Savings and Losses

Amount of Shared Savings/Losses

  • Second Agreement Period
    • Performance Year 2020, $9,556,622.94
    • Performance Year 2019, N/A
    • Performance Year 2018, N/A
  • First Agreement Period
    • Performance Year 2017, N/A
    • Performance Year 2016, $19,914,592
    • Performance Year 2015, $16,614,051

Shared Savings Distribution

  • Second Agreement Period
    • Performance Year 2020
      • Proportion invested in infrastructure: 15%
      • Proportion invested in redesigned care processes/resources: 10%
      • Proportion of distribution to ACO participants: 75%
    • Performance Year 2019
      • Proportion invested in infrastructure: N/A
      • Proportion invested in redesigned care processes/resources: N/A
      • Proportion of distribution to ACO participants: N/A
    • Performance Year 2018
      • Proportion invested in infrastructure: N/A
      • Proportion invested in redesigned care processes/resources: N/A
      • Proportion of distribution to ACO participants: N/A
  • First Agreement Period
    • Performance Year 2017
      • Proportion invested in infrastructure: N/A
      • Proportion invested in redesigned care processes/resources: N/A
      • Proportion of distribution to ACO participants: N/A
    • Performance Year 2016
      • Proportion invested in infrastructure: 5%
      • Proportion invested in redesigned care processes/resources: 5%
      • Proportion of distribution to ACO participants: 90%
    • Performance Year 2015
      • Proportion invested in infrastructure: 5%
      • Proportion invested in redesigned care processes/resources: 5%
      • Proportion of distribution to ACO participants: 90%

2020 Quality Performance Results

ACO# Measure Name Rate ACO Mean
ACO-1 CAHPS: Getting Timely Care, Appointments, and Information N/A N/A
ACO-2 CAHPS: How Well Your Providers Communicate N/A N/A
ACO-3 CAHPS: Patients’ Rating of Provider N/A N/A
ACO-4 CAHPS: Access to Specialists N/A N/A
ACO-5 CAHPS: Health Promotion and Education N/A N/A
ACO-6 CAHPS: Shared Decision Making N/A N/A
ACO-7 CAHPS: Health Status/Functional Status N/A N/A
ACO-34 CAHPS: Stewardship of Patient Resources N/A N/A
ACO-8 Risk Standardized, All Condition Readmission N/A N/A
ACO-38 All-Cause Unplanned Admissions for Patients with Multiple Chronic Conditions N/A N/A
ACO-43 Ambulatory Sensitive Condition Acute Composite (AHRQ* Prevention Quality Indicator (PQI #91)) 1.00 1.00
ACO-13 Falls: Screening for Future Fall Risk 97.40 85.00
ACO-14 Preventive Care and Screening: Influenza Immunization 92.70 76.00
ACO-17 Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention 100.00 81.70
ACO-18 Preventive Care and Screening: Screening for Depression and Follow-up Plan 54.80 71.50
ACO-19 Colorectal Cancer Screening 89.30 72.60
ACO-20 Breast Cancer Screening 90.50 74.10
ACO-42 Statin Therapy for the Prevention and Treatment of Cardiovascular Disease 81.30 83.40
ACO-27 Diabetes: Hemoglobin A1c Poor Control (>9%) 2.90 14.00
ACO-28 Controlling High Blood Pressure 71.00 72.90

Please note, the ACO-40 Depression Remission at 12 months quality measure is not included in public reporting due to low sample size.In addition, the Centers for Medicare & Medicaid Services (CMS) The Centers for Medicare & Medicaid Services (CMS) also waived the requirement for ACOs to field a CAHPS for ACOs survey for PY 2020 through the Physician Fee Schedule Final Rule for Calendar Year 2021. Additionally, CMS reverted ACO-8 Risk-Standardized, All Condition Readmission and ACO-38 Risk-Standardized Acute Admission Rates for Patients with Multiple Chronic Conditions to pay-for-reporting, given the impact of the coronavirus disease 2019 (COVID-19) public health emergency (PHE) on these measures.

Note: In the Quality Performance Results file(s) above, search for “Cleveland Clinic Medicare ACO, LLC” to view the quality performance results. This ACO can also be found by using the ACO ID A2729 in the public use files on data.cms.gov.

Payment Rule Waivers

  • Skilled Nursing Facility (SNF) 3-Day Rule Waiver:
    • Our ACO uses the SNF 3-Day Rule Waiver, pursuant to 42 CFR § 425.612.
  • Waiver for Payment for Telehealth Services:
    • Our ACO clinicians provide telehealth services using the flexibilities under 42 CFR § 425.612(f) and 42 CFR § 425.613.

Eligible SNF affiliates for the SNF 3-Day Rule Waiver include:

  • ALTERCARE OF CUYAHOGA FALLS CENTER FOR REHABILITATION & NURSING CARE, INC.
  • ALTERCARE OF HARTVILLE CENTER FOR REHABILITATION & NURSING CARE, INC.
  • ALTERCARE OF MAYFIELD VILLAGE, INC.
  • ALTERCARE OF MENTOR CENTER FOR REHABILITATION & NURSING CARE, INC.
  • ALTERCARE OF WADSWORTH CENTER FOR REHABILITATION & NURSING CARE, INC.
  • ALTERCARE POST-ACUTE REHABILITATION CENTER, INC.
  • ALTERCARE, INC.
  • ANCHOR LODGE NURSING HOME, INC.
  • ANNA MARIA OF AURORA, INC.
  • ARC WESTLAKE VILLAGE SNF, LLC
  • ATRIUM RETIREMENT CENTERS LLC
  • AURORA MANOR LIMITED PARTNERSHIP
  • AUTUMN AEGIS, INC.
  • AVON HEALTHCARE CENTER, INC.
  • BATH MANOR LIMITED PARTNERSHIP
  • BRADLEY ROAD NURSING HOME, INC.
  • BRECKSVILLE HEALTHCARE GROUP, INC.
  • BROADVIEW NURSING HOME, INC.
  • BRUNSWICK HEALTH & REHABILITATION CENTER, INC. 
  • C A S HEALTH INVESTORS, INC.
  • CARDINAL AVON, INC.
  • CENTER RIDGE NURSING HOME, INC.
  • CLEVELAND CLINIC HEALTH SYSTEM EAST REGION
  • CONCORDIA OF OHIO
  • ELIZA JENNINGS HOME
  • ELIZA JENNINGS, INC.
  • FALLS VILLAGE RETIREMENT COMMUNITY, LTD.
  • FRANKLIN BOULEVARD NURSING HOME, INC.
  • GARNETT HEALTH CAMPUS, LLC
  • GREEN VILLAGE SKILLED NURSING & REHABILITATION, LTD.
  • HEATHER KNOLL RETIREMENT VILLAGE, INC.
  • JARVIS LEASING CO., LLC
  • JENNINGS OPERATING, LLC
  • KINGSTON OF VERMILION, LLC
  • LAKEWOOD SENIOR CAMPUS, LLC
  • LODI COMMUNITY HOSPITAL
  • LORAIN MEDICAL INVESTORS LIMITED PARTNERSHIP
  • LUTHERAN HOME
  • MAIN STREET CARE CENTER, LTD.
  • MANOR CARE OF PARMA OH, LLC
  • MANORCARE HEALTH SERVICES, LLC
  • Menorah Park Center For Senior Living 
  • MENTOR HEALTH AND REHABILITATION CENTER, INC.
  • MIDDLEBURG-LEGACY PLACE, LLC
  • MUNSON HEALTHCARE, INC.
  • OHIO LIVING COMMUNITIES
  • PLEASANT LAKE NURSING HOME, INC.
  • PROGRESSIVE AURORA, LLC
  • PROGRESSIVE MEDINA, LLC
  • PROGRESSIVE ROLLING HILLS, LLC
  • R & G NURSING CARE, INC.
  • R & J Investment Co Inc.
  • RAE-ANN SUBURBAN, INC.
  • RIDGE-PLEASANT VALLEY, INC.
  • SHCP MEDINA, INC.
  • ST AUGUSTINE MANOR
  • THE MONTEFIORE HOUSING CORPORATION
  • THE OHIO MASONIC HOME
  • Village at Marymount
  • WADSWORTH POINTE HEALTHCARE GROUP, INC.
  • WELLINGTON PLACE, LLC
  • WEST SIDE DEUTSCHER FRAUEN VEREIN
  • WILLOWOOD CARE CENTER OF BRUNSWICK, INC.
  • WOMEN'S WELSH CLUBS OF AMERICA

ACO Participation Waivers:

The following information describes each arrangement for which our ACO seeks protection under the ACO Participation Waiver, including any material amendment or modification to a disclosed arrangement.

Epic Platform

  • Parties to the arrangement:
    • Cleveland Clinic Medicare ACO, LLC and eligible physicians
    • Eligible Physicians include primary care physicians participating in CCF ACO, and other physicians who: (i) serve a population that includes Medicare beneficiaries; (ii) demonstrate alignment with “the triple aim” by serving on a sub-committee of the CCF ACO or working toward the achievement of identified metrics that are complimentary to those of CCF ACO; (iii) have privileges at any CCF hospital; and (iv) satisfy any other eligibility requirements to be established by the CCF ACO.
  • Date of arrangement:
    • 12/14/2017 is the date of Board Approval; this waiver continues to be in effect.
  • Items, services, goods, or facility provided:
    • An annual license to the Epic Systems electronic health records platform and, in some cases, a one-time activation fee, as well as the Clinovations health information technology product.
  • Date and nature of any amendments to the arrangement, if applicable.
    • N/A

Clinovations

The Centers for Medicare and Medicaid Services (“CMS”) and the U.S. Department of Health and Human Services’ Office of Inspector General (“OIG”) have made available a waiver of certain federal fraud and abuse laws in connection with the operation of accountable care organizations (“ACOs”) that have entered into a participation agreement under the Medicare Shared Savings Program (“MSSP”).

In order to receive the benefit of such waiver, the governing body of the Cleveland Clinic Medicare ACO, LLC (“CCF ACO”) has made a bona fide, detailed determination that the following arrangement is reasonably related to the purposes of the MSSP.

The CCF ACO proposes to provide, at no cost, an annual license to the Epic Systems electronic health records platform (the “Epic Platform”) to enable use of the Epic Platform (the “Proposed Epic License Program”), to certain physicians (“Eligible Physicians”), some of whom already have a license to use the Epic Platform and some of whom do not. For those Eligible Physicians who do not already have a license to use the Epic Platform, CCF ACO will also pay a one-time activation fee. Eligible Physicians will include primary care physicians participating in CCF ACO, and other physicians who: (i) serve a population that includes Medicare beneficiaries; (ii) demonstrate alignment with “the triple aim” by serving on a sub-committee of the CCF ACO or working toward the achievement of identified metrics that are complimentary to those of CCF ACO; (iii) have privileges at any CCF hospital; and (iv) satisfy any other eligibility requirements to be established by the CCF ACO.

The governing body of CCF ACO approved the Proposed Epic License Program following a determination that the Proposed Epic License Program would support the purposes of the MSSP by managing and coordinating care for beneficiaries through the CCF ACO, encouraging investment in infrastructure for high quality and efficient service delivery for patients, providing enabling technology to monitor patients and access patient medical records, evaluating health needs of CCF ACO’s assigned population, and allowing for the potential for more efficient decision-making.

The Centers for Medicare and Medicaid Services (“CMS”) and the U.S. Department of Health and Human Services’ Office of Inspector General (“OIG”) have made available waivers of certain federal fraud and abuse laws in connection with the operation of accountable care organizations (“ACOs”) that have entered into a participation agreement under the Medicare Shared Savings Program (“MSSP”).

In order to receive the benefit of such waivers, the governing body of Cleveland Clinic Medicare ACO, LLC, an Ohio nonprofit limited liability company (the “Company”) has made a bona fide, detailed determination that the following arrangement is reasonably related to the purposes of the MSSP.

The Company has authorized a waiver of certain federal fraud and abuse laws for an arrangement whereby The Cleveland Clinic Foundation bears the full costs associated with the implementation of the Clinovations health information technology product for independent primary care providers, most of whom are participants in the Company but all of whom treat Medicare beneficiaries attributed to the Company (the “Arrangement”). 

The governing body of the Company authorized the application of the waiver to the Arrangement on December 14, 2017, following a determination that the Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Arrangement: (i) provides enabling technology to gain greater and more comprehensive access to patient information, which allows for the delivery of higher quality healthcare services to Medicare beneficiaries attributed to the Company; (ii) is targeted toward use for the Medicare-eligible patient population; (iii) encourages investment in infrastructure for high quality and efficient service delivery for Medicare beneficiaries attributed to the Company and maximizes the efficiency of the EpicCare Ambulatory platform; (iv) assists in managing and coordinating care for Medicare beneficiaries attributed to the Company; and (v) assists in evaluating the health needs of the Company’s assigned population.

PAC Investment

Parties to the arrangement:

  • Cleveland Clinic Medicare ACO (CCMACO), LLC, and
  • Cleveland Clinic Foundation, d/b/a Cleveland Clinic (“CCF”)

Date of arrangement:

  • 3/10/2022 is the date of Board Approval; this waiver continues to be in effect.

Items, services, goods, or facility provided:

  • An annual allocation of funds to the ACO for the purpose of a “PAC Investment,” i.e., covering the cost of salaries of professional individuals and a software license for enhanced post-acute care management and care coordination, as well as expenses related to quality reporting. The funds come from CCF’s participation in the PCF Model, a CMMI model.

Date and nature of any amendments to the arrangement, if applicable:

  • Not applicable.

Description and Board Authorization:

CCMACO desires to implement a program designed to serve the post-acute and transitional care needs of its Medicare beneficiaries through, among other things, providing care coordination and navigation, advance care planning, transitional care management, patient support during and following discharge from a skilled nursing facility, and real-time patient tracking and management throughout the continuum of care (collectively, the “PAC Investment”). In connection with the PAC Investment, CCMACO will employ approximately 10 full-time professionals (the “PAC Team”) and obtain a license for certain software to facilitate the work of the PAC Team and ACO system teams, as well as cover expenses related to quality reporting. CCMACO proposes to utilize revenue from Cleveland Clinic Foundation’s participation in the Primary Care First (“PCF”) program to fund the PAC Investment.

The governing body of CCMACO authorized the application of the waiver to the PAC Investment on March 10, 2022, following a determination that the PAC Investment supports the goals of CCF ACO and is reasonably related to the purposes of the MSSP, in each case because:

  • The PAC Investment is designed to enhance care coordination and reduce the need for avoidable acute care through, among other things, advance care planning during transitions of care and patient support following discharge from a skilled nursing facility. Addressing this historically inefficient, opaque, and costly process for patients transitioning of institutional PAC facilities improves efficiency and quality and assists in lowering the total cost of care.
  • The PAC Investment is designed to create investment in necessary information technology software to assist in effective and meaningful care coordination among providers and help ensure realization of community resources and escalation pathways.
  • The PAC Investment will help ACO Participants provide enhanced care coordination and design more efficient care processes for patients, including for Medicare beneficiaries attributed to the Company, through access to the Company’s dedicated post-acute care team of professionals.
  • Using funds earned through PCF to enhance ACO care coordination helps align the financial incentives for ACO Participants to support investment in more efficient care processes, especially because of the similarities in goals, management, and patient populations of CCF’s PCF program and the Company’s ACO.

Pharmacy Investment

Parties to the arrangement:

  • Cleveland Clinic Medicare ACO (CCMACO), LLC, and
  • Cleveland Clinic Foundation, d/b/a Cleveland Clinic (CCF)

Date of arrangement:

  • 6/9/2022 is the date of Board Approval; this waiver continues to be in effect.

Items, services, goods, or facility provided:

  • An annual allocation of funds to the ACO for the purpose of a “Pharmacy Investment,” i.e., covering the cost of salaries of two pharmacists. The funds come from CCF’s participation in the PCF Model, a CMMI model.

Date and nature of any amendments to the arrangement, if applicable:

  • Not applicable.

Description and Board Authorization:

CCMACO desires to implement a program designed to serve the needs of its Medicare beneficiaries through, among other things, a program to improve access, quality, coordination, and evidence-based care for ACO patients in need of prescribed pharmacologic therapies and disease education (collectively, the “Pharmacy Investment”). In connection with the Pharmacy Investment, CCMACO will employ approximately two full-time pharmacists (the “Pharmacists”). CCMACO proposes to utilize revenue from Cleveland Clinic Foundation’s participation in the Primary Care First (“PCF”) program to fund the Pharmacy Investment.

The governing body of CCMACO authorized the application of the waiver to the Pharmacy Investment on June 9, 2022, following a determination that the Pharmacy Investment supports the goals of CCMACO and is reasonably related to the purposes of the MSSP, in each case because:

  • The Pharmacy Investment is designed to promote accountability for the quality and cost of care by building institutional resources to promote informed choices by prescribers and patients.
  • The Pharmacy Investment is designed to improve management and coordination of care by addressing, e.g., barriers to medication adherence, risks of drug interactions and poly-pharmacy, drug affordability challenges, and lack of information about medically effective drug substitutions.
  • The Pharmacy Investment is an investment in infrastructure and redesign of care processes for high-quality and efficient service delivery, such as promoting optimal site of service for drug administration and the use of “adherence packaging” for medications, as well as broader initiatives designed to improve evidence-based medication management of diabetes, hypertension, heart failure, COPD, and chronic kidney disease.
  • Using funds earned through PCF to enhance ACO care coordination helps align the financial incentives for ACO Participants to support investment in more efficient care processes, especially because of the similarities in goals, management, and patient populations of CCF’s PCF program and the CCMACO.