Health Panel Comment Letter – ACO Proposed Rule – October 2018

RE: 42 CFR Part 414 and 425: Medicare Program; Medicare Shared Savings Program; Accountable Care
Organizations – Pathways to Success

The Panel is pleased to offer comments in response to this particular proposed rule. Our comments are limited to rural-specific issues and are structured to parallel questions posed, or issues stated, by CMS (not technical comments regarding specific sections of the proposed rule).

Overall, the Panel supports efforts to improve the Medicare Shared Savings Program, and other issues
highlighted in this proposed rule. Medicare represents a higher proportion of patients for most rural health
care organizations and clinicians than in urban areas, so Medicare policies may have a disproportionate impact
on rural providers, hospitals, and beneficiaries.

View Comment Letter