About

IHACO Governing Body:

Please note, the Quality ID #: 370 Depression Remission at 12 months quality measure is not included in public reporting due to low sample size.

Please note, the ACO-40 Depression Remission at 12 months quality measure is not included in public reporting due to low samples and the ACO-36 All-Cause Unplanned Admissions for Patients with Diabetes quality measure is not included in public reporting due to a non-material technical error.

• For 2017 Quality Performance Results please visit:
  https://data.cms.gov/Special-Programs-Initiatives-Medicare-Shared-Savin/2017-Shared-Savings-Program-SSP-Accountable-Care-O/gk7c-vejx/data
• For 2016 Quality Performance Results please visit:
  https://data.cms.gov/Special-Programs-Initiatives-Medicare-Shared-Savin/2016-Shared-Savings-Program-SSP-Accountable-Care-O/3jk5-q6dr/data
• For 2015 Quality Performance Results please visit:
  https://data.cms.gov/Special-Programs-Initiatives-Medicare-Shared-Savin/Medicare-Shared-Savings-Program-Accountable-Care-O/x8va-z7cu/data
• For 2014 Quality Performance Results please visit:
  https://data.cms.gov/Special-Programs-Initiatives-Medicare-Shared-Savin/Medicare-Shared-Savings-Program-Accountable-Care-O/ucce-hhpu/data
• For 2013 Quality Performance Results please visit:
  https://data.cms.gov/Special-Programs-Initiatives-Medicare-Shared-Savin/Medicare-Shared-Savings-Program-Accountable-Care-O/yuq5-65xt/data

Note: In the Quality Performance Results file(s) above, search for “Independence Health Accountable Care Organization” to view the quality performance results. This ACO can also be found by using the ACO ID A71510 in the public use files on data.cms.gov.

Public Website Disclosure Statements

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 are planning to enter into or 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 Northwest Ohio ACO, LLC  (the “Company”) made a bona fide, detailed determination on [DATE] that each of the arrangements described further below are reasonably related to the purposes of the MSSP and authorized the arrangements for protection by a waiver of federal fraud and abuse laws made available by CMS and OIG.

Durable Medical Equipment Arrangement

The Company has authorized an arrangement whereby The Toledo Clinic, Inc. (“TTC”), through TTC and/or its pharmacy (neither of which is primarily engaged in the provision of durable medical equipment), provides durable medical equipment to patients who are Medicare or Medicaid beneficiaries, including Medicare beneficiaries attributed to the Company (the “Durable Medical Equipment Arrangement”).

The governing body of the Company authorized the application of the waiver to the Durable Medical Equipment Arrangement on [DATE], following a determination that the Durable Medical Equipment Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Durable Medical Equipment Arrangement:

(i) assists in the coordination of care across all of TTC’s service offerings for its patients, including for Medicare beneficiaries attributed to the Company, which allows for the delivery of higher quality health care services;

(ii) allows for greater access to preventive care items in the community, including for Medicare beneficiaries attributed to the Company;

(iii) advances adherence to a treatment regime, adherence to a follow-up care plan, and/or management of a chronic disease or condition for TTC patients, including for Medicare beneficiaries attributed to the Company; and

(iv) allows patients, including Medicare beneficiaries attributed to the Company, to have a cost-efficient alternative for durable medical equipment items and supplies.

Cardiology Ancillary Services Allocation:

The Company has authorized an arrangement involving the allocation of ancillary revenues among The Toledo Clinic, Inc.’s (“TTC”) cardiologists (the “Cardiology Ancillary Services Allocation Arrangement”).

The governing body of the Company authorized the application of the waiver to the Cardiology Ancillary Services Allocation Arrangement on [DATE], following a determination that the Cardiology Ancillary Services Allocation Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Cardiology Ancillary Services Allocation Arrangement:

(i) assists in the coordination of care across TTC’s cardiology service offerings for its patients, including for Medicare beneficiaries attributed to the Company, which allows for the delivery of higher quality health care services;

(ii) assists in reducing the costs of health care for patients, including for Medicare beneficiaries attributed to the Company, by treating patients outside of the hospital setting and reducing the number of medically unnecessary procedures;

(iii) enhances physician engagement for driving true performance and clinical integration among physicians in the community;

(iv) promotes timely reads of patient medical results; and

(v) promotes widespread use of an electronic medical record platform across TTC.

Physician Recruitment Arrangement

The Company has authorized an arrangement involving the allocation of an amount of the Company’s CMS shared savings distribution for ACO participants to invest in physician recruitment, including the provision of start-up income guarantees and/or bonuses for primary care physicians and certain specialists and bonuses to residents in compliance with applicable law in exchange for their commitment to remain in Northwest Ohio after graduation from residency (the “Physician Recruitment Arrangement”).

The governing body of the Company authorized the application of the waiver to the Physician Recruitment Arrangement on [DATE], following a determination that the Physician Recruitment Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Physician Recruitment Arrangement:

(i) assists in the coordination of care across service offerings for all MSSP ACO patients, as well as other patients in the community, including for Medicare beneficiaries attributed to the Company, which allows for the delivery of higher quality health care services;

(ii) assists in reducing the costs of health care for patients, including Medicare beneficiaries attributed to the Company, by treating patients outside the hospital setting and reducing the number of medically unnecessary procedures;

(iii) enhances physician engagement for driving true performance and clinical integration among physicians in the community by contractually requiring participating providers to coordinate patient care and satisfy certain quality and utilization metrics;

(iv) enhances access to primary care and specialty services in the community, including for Medicare beneficiaries attributed to the Company, and provides additional health care services to the community, which allows for more opportunities for care coordination and the delivery of higher quality health care services;

(v) promotes widespread use of an electronic medical record platform (“EMR”) closely connected with the Company, and allows physicians to timely read patient medical, lab, and imaging results, as well as enhances coordination of care; and

(vi) encourages investment in infrastructure for high quality and efficient service delivery for patients, including Medicare beneficiaries attributed to the Company, by relocating and adding more PCPs and specialists to the community.

 Community Surgeon ASC Arrangement

The Company has authorized an arrangement involving the provision of profit shares of the The Toledo Clinic, Inc. (“TTC”) ambulatory surgery center to non-TTC surgeons that contractually commit to participating in coordinating patient care and certain quality and utilization metrics (the “Community Surgeon ASC Arrangement”).

The governing body of the Company authorized the application of the waiver to the Community Surgeon ASC Arrangement on [DATE], following a determination that the Community Surgeon ASC Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Community Surgeon ASC Arrangement:

(i) assists in the coordination of care across service offerings for all MSSP ACO patients, as well as other patients in the community, including for Medicare beneficiaries attributed to the Company, which allows for the delivery of higher quality health care services;

(ii) assists in reducing the costs of health care for patients, including Medicare beneficiaries attributed to the Company, by treating patients outside the hospital setting and reducing the number of medically unnecessary procedures;

(iii) enhances physician engagement for driving true performance and clinical integration among physicians in the community by contractually requiring participating providers to coordinate patient care and satisfy certain quality and utilization metrics;

(iv) enhances access to primary care and specialty services in the community, including for Medicare beneficiaries attributed to the Company, and provide additional health care services to the community, which allows for more opportunities for care coordination and the delivery of higher quality health care services;

(v) promotes widespread use of an electronic medical record platform (“EMR”) closely connected with the Company, and allow physicians to timely read patient medical, lab, and imaging results, as well as enhance coordination of care; and

(vi) encourages investment in infrastructure for high quality and efficient service delivery for patients, including Medicare beneficiaries attributed to the Company, by relocating and adding more PCPs and specialists to the community.

DCC Arrangement:

The Company has authorized an arrangement for a patient coordination project involving The Toledo Clinic, Inc. (“TTC”), Toledo Clinic Cancer Centers (“TCCC”), and The University of Toledo Medical Center’s Eleanor N. Dana Cancer Center (“DCC”), whereby the parties desire to coordinate care for oncology patients through the provision of necessary professional healthcare services and pharmaceutical oncology drugs (the “DCC Arrangement”).

The governing body of the Company authorized the application of the waiver to the DCC Arrangement on [DATE], following a determination that the DCC Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the DCC Arrangement:

(i) expands access to lower cost of care for governmental and underinsured patients, including Medicare beneficiaries attributed to the Company;

(ii) improves access to care by increasing a specialized skillset and creating a larger physician network profile for similar populations;

(iii) improves the coordination of specialty and primary care;

(iv) improves the transparency of pharmacy costs; and

(v) increases resources and the capacity to assist insured and uninsured patients, including Medicare beneficiaries attributed to the Company.

Micro-ASC Arrangement:

The Company has authorized an arrangement for a revised compensation model for The Toledo Clinic, Inc.’s (“TTC”) outpatient surgery center (the “ASC”) that allows TTC to allocate revenues and expenses on a specialty-by-specialty basis, initially as it relates to Urology, GI, General Surgery, and ENT (the “Micro-ASC Arrangement”).  Each surgeon and proceduralist that participates in the Micro-ASC Arrangement would sign a care coordination agreement containing quality and other performance metrics.

The governing body of the Company authorized the application of the waiver to the Micro-ASC Arrangement on [DATE], following a determination that the Micro-ASC Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Micro-ASC Arrangement:

(i) reduces health care costs by treating Medicare beneficiaries (including those attributed to the Company) in a lower cost of care setting (i.e., ASC instead of hospital);

(ii) creates efficiencies in reducing number of ASCs at which proceduralists provide care, avoiding undue proliferation of ASCs in the service area of the Company, and driving wise capital investment decision-making; and

(iii) drives clinical integration, care coordination, and quality among physicians at the ASC, as documented in the written care coordination agreement with each physician.

Group Practice Compensation Arrangement

In an effort to promote better quality, efficiency, patient satisfaction, and utilization of infrastructure with respect to The Toledo Clinic, Inc’s (“TTC”) ancillary service lines, the Company has authorized the following arrangements involving a series of group practice compensation methodologies, including (each individually, a “Group Practice Arrangement” and collectively, the “Group Practice Arrangements”)

• In-Office Laboratory Services Compensation Methodology – intended to allow certain primary care physicians employed by The Toledo Clinic, Inc. (“TTC”) to directly receive profits associated with CLIA-exempt laboratory services performed by a duly-qualified and appropriately-trained non-physician provider in TTC’s in-office laboratory, which promotes more efficient health care delivery to patients by allowing physicians to focus on providing care to patients.
• Mohs Surgery Compensation Methodology – intended to allow dermatology surgeons (whether employed by TTC or by Toledo Clinic, PLL) to directly receive profits from certain services related to Mohs surgical procedures performed by a duly-qualified and appropriately-trained non-physician provider in the office, and pathology services performed by a duly-qualified and appropriately trained pathologist/dermapathologist reviewing slides remotely and contemporaneously with the Mohs surgery (whether such non-physician providers or dermatologists are employed by TTC directly, or by Toledo Clinic, PLLC), which promote more efficient health care delivery to patients by allowing physicians to focus on providing care to patients, decreasing average total time per surgery, and enabling dermatology surgeon(s) to schedule more patients awaiting the Mohs procedure.
• ENT Imaging Compensation Methodology – intended to allow ENT physicians employed by TTC to directly receive profits from imaging services using TTC’s in-office CT scanner associated with the ENT offices at the TTC, which promotes utilization of infrastructure and cost-efficiencies through patients receiving services at sites with lower costs of care.
• Gynecological Imaging Compensation Methodology – intended to allow GYN physicians employed by TTC to directly receive profits from imaging services using TTC’s in-office Dexa and Ultrasound scanners associated with the GYN offices at the TTC, which promotes utilization of infrastructure and cost-efficiencies through patients receiving services at sites with lower costs of care.
• Endocrinology Imaging Compensation Methodology – intended to allow endocrinology physicians employed by TTC to directly receive profits from imaging services using TTC’s in-office Dexa and Ultrasound scanners associated with the endocrinology offices at the TTC, which promotes utilization of infrastructure and cost-efficiencies through patients receiving services at sites with lower costs of care.
• Rheumatology Imaging Compensation Methodology – intended to allow rheumatology physicians employed by TTC to directly receive profits from imaging services using TTC’s in-office x-ray and Dexa scanners associated with the rheumatology offices at the TTC, which promotes utilization of infrastructure and cost-efficiencies through patients receiving services at sites with lower costs of care.
• General Surgery Imaging Compensation Methodology – intended to allow general surgeons employed by TTC to directly receive profits from imaging services using TTC’s in-office Ultrasound scanners associated with the general surgery offices at the TTC, which promotes utilization of infrastructure and cost-efficiencies through patients receiving services at sites with lower costs of care.
• Orthopedic Imaging Compensation Methodology – intended to allow orthopedic physicians employed by TTC to directly receive profits from imaging services using TTC’s in-office x-ray scanners associated with the orthopedic offices at the TTC, which promotes utilization of infrastructure and cost-efficiencies through patients receiving services at sites with lower costs of care.
• Rheumatology Infusion Compensation Methodology – intended to allow rheumatology physicians employed by TTC to directly receive profits from infusion services using TTC’s in-office infusion suites associated with the rheumatology offices at the TTC, which promotes utilization of infrastructure and allows for the delivery of higher quality services while reducing the cost of health care by treating patients outside of a hospital setting.
• Laboratory and Pathology Compensation Methodology – intended to allow all physicians employed by TTC to directly receive profits from laboratory and pathology services using TTC’s in-office laboratory and pathology departments at the TTC, in a manner similar to how physicians received such profits in the past, which promotes utilization of infrastructure, assists in coordination of care, and allows for the delivery of higher quality services while reducing the cost of health care by treating patients outside of a hospital setting.
• Oncology Department Pharmacy Compensation Methodology – intended to allocate profits associated with TTC’s Oncology Department pharmacy on an equal basis among all of the medical oncologists employed by TTC, which promotes utilization of infrastructure and improves the coordination of specialty care.

In connection with the foregoing, TTC and Company will also enter into a Care Coordination Agreement, pursuant to which TTC will provide care coordination services to Company so that beneficiaries attributed to Company receiving health care services from TTC and its physicians in connection with the Group Practice Arrangements experience service delivery in a manner that promotes the “triple aim.”

The governing body of the Company authorized the application of the waiver to the Group Practice Arrangements on [DATE], following a determination that the Group Practice Arrangements support the goals of the Company and are reasonably related to the purposes of the MSSP, in each case because each of the In-Office Laboratory Services Compensation Methodology, Mohs Surgery Compensation Methodology, ENT Imaging Compensation Methodology, Gynecological Imaging Compensation Methodology, Endocrinology Imaging Compensation Methodology, Rheumatology Imaging Compensation Methodology, General Surgery Imaging Compensation Methodology, Orthopedic Imaging Compensation Methodology, Rheumatology Infusion Compensation Methodology, Laboratory and Pathology Compensation Methodology, and Oncology Department Pharmacy Compensation Methodology:

(i) promotes better quality, efficiency, patient satisfaction, and utilization of infrastructure with respect to TTC’s ancillary service lines;

(ii) drives clinical integration, care coordination, and quality among TTC’s physicians;

(iii) allows for care coordination so that all patients, including Medicare beneficiaries attributed to Company, experience service delivery in a manner that promotes the “triple aim”; and

(iv) provides opportunities for treatment at sites with lower costs of care.

Urology Pharmacy Arrangement

The Company has authorized an arrangement that relates to Uro Pharmacy, LLC (the “Pharmacy”), an independent pharmacy supporting a division of the Urology Department of the Toledo Clinic, Inc. (“TTC”).  This Urology Department Pharmacy Compensation Methodology and Prescription Delivery Arrangement (the “Urology Pharmacy Arrangement”) is intended to allocate profits associated with a division of TTC’s Urology Department pharmacy on an equal basis among members of  such division of the Urology Department, which promotes utilization of infrastructure and improves the coordination of specialty care; it is intended also to offer a pharmacy prescription delivery service to patients’ homes, which promotes more efficient health care delivery by delivering prescription medications directly to patients, increasing patient medication adherence rates, and enabling on-site pharmacists and technicians to dedicate more time for consultations and filling orders.

In connection with the foregoing, TTC, the Pharmacy, and Company will enter into a Urology Pharmacy Care Coordination Agreement, pursuant to which TTC and the Pharmacy will provide care coordination services to Company so that beneficiaries attributed to Company receiving health care services from TTC and its physicians in connection with the Urology Pharmacy Arrangement experience service delivery in a manner that promotes the “triple aim.”  TTC and the Pharmacy will also enter into a Services Agreement, pursuant to which TTC will manage day-to-day non-clinical business operations of the Pharmacy’s location at 3355 Meijer Road to further facilitate the value-based activities set forth in such Services Agreement..

The governing body of the Company authorized the application of the waiver to the Urology Pharmacy Arrangement on [DATE], following a determination that the Urology Pharmacy Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, because the Urology Pharmacy Arrangement:

(i) promotes better quality, efficiency, patient satisfaction, and utilization of infrastructure with respect to TTC’s ancillary service lines;

(ii) drives clinical integration, care coordination, and quality among TTC’s physicians,

(iii) allows for care coordination so that all patients, including Medicare beneficiaries attributed to Company, experience service delivery in a manner that promotes the “triple aim”; and

(iv) provides opportunities for treatment at sites with lower costs of care.