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.

Payment Rule Waivers

• Yes, our ACO will begin using the SNF 3-day waiver on 1/1/2020.
• Participation Waiver
  • 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 Pathways to Success (“MSSP”).
  • In order to receive the benefit of such waivers, the governing body of Independence Health Accountable Care Organization (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 a patient coordination project involving The Toledo Clinic (“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 “Arrangement”).

  • The governing body of the Company authorized the application of the waiver to the Arrangement on November 10, 2020, 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) 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.
• Participation Waiver
  • 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 Pathways to Success (“MSSP”).
  • In order to receive the benefit of such waivers, the governing body of Independence Health Accountable Care Organization (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 the following arrangements (the “Arrangements”):
    • Allocation of an amount of up to the entire amount of the Company’s agreed upon 20% set-aside of the 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 (“PCPs”) 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;
    • Provision of profit shares of the Toledo Clinic ambulatory surgery center to non-Toledo Clinic surgeons that contractually commit to participating in coordinating patient care and certain quality and utilization metrics; and
    • Provision of a care coordination bonus to community PCPs that contractually agree to care coordination and certain quality and utilization metrics.
  • The governing body of the Company authorized the application of the waiver to the Arrangements on November 12, 2019, following a determination that the Arrangements support the goals of the Company and is reasonably related to the purposes of the MSSP, in each case because the Arrangements: (i) assist 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 Northwest Ohio ACO, which allows for the delivery of higher quality healthcare services; (ii) assist in reducing the costs of healthcare for patients, including Medicare beneficiaries attributed to Northwest Ohio ACO, by treating patients outside the hospital setting and reducing the number of medically unnecessary procedures; (iii) enhance 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) enhance access to primary care and specialty services in the community, including for Medicare beneficiaries attributed to Northwest Ohio ACO, and provide additional healthcare services to the community, which allows for more opportunities for care coordination and the delivery of higher quality healthcare services; (v) promote 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) encourage investment in infrastructure for high quality and efficient service delivery for patients, including Medicare beneficiaries attributed to Northwest Ohio ACO, by relocating and adding more PCPs and specialists to the community.
• Participation Waiver
  • Centers for Medicare and Medicaid Services (“CMS”) finalized rules under the Patient Protection and Affordable Care Act that establish the Medicare Shared Savings Program Pathways to Success (“MSSP”), which helps physicians, hospitals, and other health care providers better coordinate care for Medicare beneficiaries through the development of accountable care organizations (“ACOs”) that seek to achieve the “triple aims” of health care reform—better care for individuals, better health for populations, and lower growth in health care expenditures (the “Triple Aim”)
  • In an effort to promote better quality, efficiency, patient satisfaction, and utilization of infrastructure with respect to Toledo Clinic’s ancillary service lines, Toledo Clinic desires to modify its group practice compensation methodology to allow profits associated with certain designated health services for specific Toledo Clinic ancillary service lines to be allocated to its employed physicians, subject to satisfaction of quality and other performance metrics, including utilization safeguards
  • Such arrangement effectively positions the Toledo Clinic’s group practice compensation methodology in a way that is compliant with the Stark Law prior to CMS’s Final Rule set forth at 85 Fed. Reg. 77492 (December 2, 2020), effective January 1, 2022, modifying the special rules for profit shares for group practices under 42 C.F.R. § 352(i), including:
  • 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
  • Oncology Department Pharmacy Compensation Methodology
• DME Waiver
  • 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”).
  • I In order to receive the benefit of such waivers, the governing body of Independence Health Accountable Care Organization (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 Toledo Clinic, Inc. (“TTC”), through TTC and/or its pharmacy, provides durable medical equipment (“DME”) to patients who are Medicare or Medicaid beneficiaries, including Medicare beneficiaries attributed to the Company (the “Arrangement”).
  • The governing body of the Company authorized the application of the waiver to the Arrangement on October 10, 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) assists in the coordination of care across all of TTC’sservice offerings for its patients, including for Medicare beneficiaries attributed to the Company, which allows for the delivery of higher quality healthcare 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 DME items and supplies.
• Cardiology Revenue Allocation
  • 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 Independence Health Accountable Care Organization (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 involving the allocation of ancillary revenues among The Toledo Clinic, Inc.’s (“TTC”) cardiologists (the “Arrangement”).
  • The governing body of the Company authorized the application of the waiver to the Arrangement on November 13, 2018, 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) 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 healthcare services; (ii) assists in reducing the costs of healthcare 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.
• Patient Coordination Project with Neighborhood Health Association
  • 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 aparticipation agreement under the Medicare Shared Savings Program Pathways to Success (“MSSP”).
  • In order to receive the benefit of such waivers, the governing body of Independence Health Accountable Care Organization (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 a patient coordination project involving The Toledo Clinic (“TTC”), Toledo Clinic Cancer Centers (“TCCC”), and Neighborhood Health Association (“NHA”), whereby the parties desire to coordinate care for oncology patients through the provision of necessary professional healthcare services and pharmaceutical oncology drugs (the “Arrangement”).
  • The governing body of the Company authorized the application of the waiver to the Arrangement on June 9, 2020, 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) 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
  • 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 Pathways to Success (“MSSP”).
  • In order to receive the benefit of such waivers, the governing body of Independence Health Accountable Care Organization (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 to a revised compensation model for Toledo Clinic’s outpatient surgery center (the “ASC”) that allows Toledo Clinic to allocate revenues and expenses on a specialty-by-specialty basis (the “Arrangement”). Each surgeon and proceduralist that participates in the 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 Arrangement on January 1, 2022, 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) 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.

• Mohs Arrangement

  • 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 Pathways to Success (“MSSP”).
  • In order to receive the benefit of such waivers, the governing body of Northwest Ohio ACO, LLC d/b/a Independence Health Accountable Care Organization (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 to a series of group practice compensation methodologies for Toledo Clinic, Inc. (“Toledo Clinic”), including the Mohs Arrangement (hereinafter defined) (collectively, the “Arrangement”):
  • Mohs Surgery Compensation Methodology – intended to allow dermatology surgeon(s) (whether employed by Toledo Clinic directly, or by Toledo Clinic, PLLC) to directly receive profits from certain services related to Mohs surgical procedures, including laboratory services 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/dermatopathologist  reviewing slides remotely and contemporaneously with the Mohs surgery (whether such non-physician providers or dermatologists are employed by Toledo Clinic 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. Patient Satisfaction; Patient Access, Turnaround Time (“Mohs Arrangement”).
  • In connection with the foregoing, Toledo Clinic and Company will also enter into an Amended Care Coordination Agreement, pursuant to which Toledo Clinic will provide care coordination services to Company so that beneficiaries attributed to Company receiving health care services from Toledo Clinic and its physicians in connection with the Arrangement 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 Arrangement on March 7, 2024 following a determination that the Arrangement supports the goals of the Company and is reasonably related to the purposes of the MSSP, because the Mohs Arrangement (i) promotes better quality, efficiency, patient satisfaction, and utilization of infrastructure with respect to Toledo Clinic’s ancillary service lines, (ii) drives clinical integration, care coordination, and quality among Toledo Clinic’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.