Address

4235 Secor Rd.
Toledo, OH 43623

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About

IHACO Location

Independence Health Accountable Care Organization
4235 Secor Rd
Toledo, OH 43623

IHACO Primary Contact

Chris Santoro
419-318-9447
csantoro@toledoclinic.com

Organizational Information


IHACO Participants


IHACO Participant in Joint Venture

Toledo Clinic Incorporated

Y

Northwest Surgical Specialists Inc

Y

James M Croak DO, Inc

Y

Alliance Retina, LLC

Y

Wood Health Company LLC Y
Wood County Womens Care of Bowling Green, LLC Y

IHACO Governing Body:


Member


Member’s Voting Power


Membership Type


IHACO Participant TIN Legal Business Name/DBA, if
Applicable


Last Name


First Name


Title/Position

Elliot

Ian

President

1

Board

Toledo Clinic, Inc.

Jacob

Moshir

CMO

1

Board

Toledo Clinic, Inc.

Sternfeld

William

 

1

Board

Toledo Clinic, Inc.

Bais

Sanjiv

 

1

Board

Toledo Clinic, Inc.

Naddaf

Henry

 

1

Board

Toledo Clinic, Inc.

Rao

Upamaka

 

1

Board

Toledo Clinic, Inc.

Salem

Mazin

 

1

Board

Toledo Clinic, Inc.

Dyer

Patrick

 

1

Board

Toledo Clinic, Inc.

Wyatt

Duane

 

1

Board

Medicare Beneficiary Representative

Bell

Wayne

1

Board

Wood Health Company LLC

Korducki

Stan

1

Board

Wood Health Company LLC

Key IHACO clinical and administrative leadership

Chris Santoro

ACO Executive Director

Moshir Jacob, MD

Medical Director

Peter Stanos, MD

Compliance Officer

Moshir Jacob, MD

Quality Assurance/Improvement Officer

Associated committees and committee leadership:Associated committees and committee leadership


Committee Name


Committee Leader Name and Position

Quality Committee

Moshir Jacob, MD.

Compliance Committee

Peter Stanos, MD.

Types of IHACO participants or combinations of participants that form IHACO

  • ACO professionals in a group practice arrangement
  • Network of Individual practices of ACO professionals
  • Shared Savings and Losses:

    Amount of Shared Savings/Losses

    • Third Agreement Period

      • Performance Year 2020, $1,920,007
      • Performance Year 2019-A, $0

    • Second Agreement Period
      • Performance Year 2019, $2,569,151
      • Performance Year 2018, $5,048,226
      • Performance Year 2017, $3,447,479
      • Performance Year 2016, $3,384,906
    • First Agreement Period

      • Performance Year 2015, $0
      • Performance Year 2014, $0
      • Performance Year 2013, $0

    IHIHShared Savings Distribution

    • Third Agreement Period
      • Performance Year 2019-A
        • Proportion invested in infrastructure: N/A
        • Proportion invested in redesigned care processes/resources: N/A
        • Proportion of distribution to IHACO participants: N/A
    • Second Agreement Period
      • Performance Year 2019
        • Proportion invested in infrastructure: 39%
        • Proportion invested in redesigned care processes/resources: 20%
        • Proportion of distribution to IHACO participants: 41%
      • Performance Year 2018
        • Proportion invested in infrastructure: 20%
        • Proportion invested in redesigned care processes/resources: 20%
        • Proportion of distribution to IHACO participants: 60%
      • Performance Year 2017
        • Proportion invested in infrastructure: 29%
        • Proportion invested in redesigned care processes/resources: 20%
        • Proportion of distribution to IHACO participants: 51%
      • Performance Year 2016
        • Proportion invested in infrastructure: N/A
        • Proportion invested in redesigned care processes/resources: 20%
        • Proportion of distribution to IHACO participants: 80%
    • First Agreement Period
      • Performance Year 2015
        • Proportion invested in infrastructure: N/A
        • Proportion invested in redesigned care processes/resources: N/A
        • Proportion of distribution to IHACO participants: N/A
      • Performance Year 2014
        • Proportion invested in infrastructure: N/A
        • Proportion invested in redesigned care processes/resources: N/A
        • Proportion of distribution to IHACO participants: N/A

        Performance Year 2013

        • Proportion invested in infrastructure: N/A
        • Proportion invested in redesigned care processes/resources: N/A
        • Proportion of distribution to IHACO participants: N/A

    Quality Performance Results

    2020 Quality Performance Results:



    ACO#



    Measure Name



    Rate



    ACO Mean


    ACO-8

    Risk Standardized, All
    Condition Readmission


    14.58


    15.07


    ACO-38


    Risk-Standardized Acute Admission Rates for Patients with Multiple
    Chronic Conditions


    49.63


    49.50


    ACO-43


    Ambulatory Sensitive Condition Acute Composite (AHRQ* Prevention
    Quality Indicator (PQI #91))


    0.90


    0.95


    ACO-13


    Falls: Screening for Future Fall Risk


    90.19


    84.97


    ACO-14


    Preventive Care and Screening: Influenza Immunization


    74.12


    76.03


    ACO-17


    Preventive Care and Screening: Tobacco Use: Screening and Cessation
    Intervention


    95.65


    81.67


    ACO-18


    Preventive Care and Screening: Screening for Depression and
    Follow-up Plan


    79.58


    71.46


    ACO-19


    Colorectal Cancer Screening


    81.26


    72.59


    ACO-20


    Breast Cancer Screening


    76.40


    74.05


    ACO-42


    Statin Therapy for the Prevention and Treatment of Cardiovascular
    Disease


    88.85


    83.37


    ACO-40


    Depression Remission at Twelve Months


    4.62


    13.99


    ACO-27


    Diabetes Mellitus: Hemoglobin A1c Poor Control


    12.83


    14.70


    ACO-28


    Hypertension (HTN): Controlling High Blood Pressure


    69.54


    72.87

    2019 Quality Performance Results:



    ACO#



    Measure Name



    Rate



    ACO Mean


    ACO-1


    CAHPS: Getting Timely Care, Appointments, and
    Information


    85.89


    85.86


    ACO-2


    CAHPS: How Well Your Providers Communicate


    94.57


    94.11


    ACO-3


    CAHPS: Patients’ Rating of Provider


    92.31


    92.69


    ACO-4


    CAHPS: Access to Specialists


    82.83


    81.54


    ACO-5


    CAHPS: Health Promotion and Education


    64.54


    60.44


    ACO-6


    CAHPS: Shared Decision Making


    71.42


    62.78


    ACO-7


    CAHPS: Health Status/Functional Status


    75.66


    73.79


    ACO-34


    CAHPS: Stewardship of Patient Resources


    29.95


    26.17


    ACO-45


    CAHPS: Courteous and Helpful Office Staff


    92.16


    92.84


    ACO-8


    Risk Standardized, All Condition


    Readmission


    14.74


    14.86


    ACO-38


    All-Cause Unplanned Admissions for Patients with Multiple Chronic
    Conditions


    55.56


    58.15


    ACO-43


    Ambulatory Sensitive Condition Acute Composite (AHRQ Prevention
    Quality Indicator (PQI) #91)


    2.12


    1.87


    ACO-13


    Falls: Screening for Future Fall Risk


    90.07


    84.04


    ACO-14


    Preventive Care and Screening: Influenza Immunization


    71.82


    74.77


    ACO-17


    Preventive Care and Screening: Tobacco Use: Screening and Cessation
    Intervention


    87.10


    78.04


    ACO-18


    Preventive Care and Screening: Screening for Clinical Depression and
    Follow-up Plan


    85.16


    70.40


    ACO-19


    Colorectal Cancer Screening


    75.37


    70.76


    ACO-20


    Breast Cancer Screening


    78.63


    73.84


    ACO-42


    Statin Therapy for the Prevention and Treatment of Cardiovascular
    Disease


    85.47


    82.17


    ACO-40


    Depression Remission at Twelve Months


    6.15


    13.58


    ACO-27


    Diabetes Mellitus: Hemoglobin A1c Poor Control


    15.02


    13.88


    ACO-28


    Hypertension (HTN): Controlling High Blood Pressure


    75.10


    75.04

    2018 Quality Performance Results:



    ACO#



    Measure Name



    Rate



    ACO Mean


    ACO-1


    CAHPS: Getting Timely Care, Appointments, and Information


    85.30


    86.14


    ACO-2


    CAHPS: How Well Your Providers Communicate


    93.72


    93.93


    ACO-3


    CAHPS: Patients’ Rating of Provider


    92.50


    92.45


    ACO-4


    CAHPS: Access to Specialists


    83.09


    81.50


    ACO-5


    CAHPS: Health Promotion and Education


    60.68


    59.26


    ACO-6


    CAHPS: Shared Decision Making


    69.41


    61.94


    ACO-7


    CAHPS: Health Status/Functional Status


    73.93


    73.35


    ACO-34


    CAHPS: Stewardship of Patient Resources


    31.06


    26.26


    ACO-8


    Risk Standardized, All Condition Readmission


    14.57


    14.98


    ACO-35


    Skilled Nursing Facility 30-day All-Cause Readmission measure
    (SNFRM)


    18.61


    18.59


    ACO-36


    All-Cause Unplanned Admissions for Patients with Diabetes


    34.32


    37.01


    ACO-37


    All-Cause Unplanned Admissions for Patients with Heart Failure


    70.66


    76.75


    ACO-38


    All-Cause Unplanned Admissions for Patients with Multiple Chronic
    Conditions


    56.91


    59.00


    ACO-43


    Ambulatory Sensitive Condition Acute Composite (AHRQ Prevention
    Quality Indicator (PQI) #91)


    2.26


    1.98


    ACO-11


    Use of Certified EHR Technology


    99.78


    98.20


    ACO-12


    Medication Reconciliation Post-Discharge


    98.71


    85.91


    ACO-13


    Falls: Screening for Future Fall Risk


    84.91


    79.73


    ACO-44


    Use of Imaging Studies for Low Back Pain


    60.00


    64.36


    ACO-14


    Preventive Care and Screening: Influenza Immunization


    62.92


    72.71


    ACO-15


    Pneumonia Vaccination Status for Older Adults


    80.73


    75.97


    ACO-16


    Preventive Care and Screening: Body Mass Index (BMI) Screening and
    Follow Up


    86.06


    76.83


    ACO-17


    Preventive Care and Screening: Tobacco Use: Screening and Cessation
    Intervention


    67.44


    72.81


    ACO-18


    Preventive Care and Screening: Screening for Clinical Depression and
    Follow-up Plan


    65.28


    66.74


    ACO-19


    Colorectal Cancer Screening


    63.29


    68.27


    ACO-20


    Breast Cancer Screening


    71.04


    71.96


    ACO-42


    Statin Therapy for the Prevention and Treatment of Cardiovascular
    Disease


    83.53


    81.47


    ACO-27


    Diabetes Mellitus: Hemoglobin A1c Poor Control


    13.65


    15.51


    ACO-41


    Diabetes: Eye Exam


    62.25


    52.42


    ACO-28


    Hypertension (HTN): Controlling High Blood Pressure


    72.96


    73.10


    ACO-30


    Ischemic Vascular Disease (IVD): Use of Aspirin or Another
    Antiplatelet


    94.74


    88.92

    2017 Quality Performance Results:


    ACO#


    Measure Name


    Rate


    ACO Mean

    ACO-1

    CAHPS: Getting Timely Care, Appointments, and Information

    81.05

    80.60

    ACO-2

    CAHPS: How Well Your Providers Communicate

    92.84

    93.13

    ACO-3

    CAHPS: Patients’ Rating of Provider

    91.89

    92.31

    ACO-4

    CAHPS: Access to Specialists

    83.92

    83.32

    ACO-5

    CAHPS: Health Promotion and Education

    62.23

    62.30

    ACO-6

    CAHPS: Shared Decision Making

    73.49

    75.85

    ACO-7

    CAHPS: Health Status/Functional Status

    73.15

    73.05

    ACO-34

    CAHPS: Stewardship of Patient Resources

    30.62

    25.68

    ACO-8

    Risk Standardized, All Condition Readmission

    14.73

    15.01

    ACO-35

    Skilled Nursing Facility 30-day All-Cause Readmission measure (SNFRM)

    19.10

    18.46

    ACO-36

    All-Cause Unplanned Admissions for Patients with Diabetes

    52.20

    53.95

    ACO-37

    All-Cause Unplanned Admissions for Patients with Heart Failure

    75.12

    79.16

    ACO-38

    All-Cause Unplanned Admissions for Patients with Multiple Chronic
    Conditions

    60.62

    61.74

    ACO-43

    Ambulatory Sensitive Condition Acute Composite (AHRQ* Prevention
    Quality Indicator (PQI #91))

    2.10

    1.93

    ACO-11

    Use of Certified EHR Technology

    100.00

    98.48

    ACO-12

    Medication Reconciliation

    91.00

    75.32

    ACO-13

    Falls: Screening for Future Fall Risk

    77.57

    74.38

    ACO-44

    Imaging Studies for Low Back Pain

    51.85

    67.32

    ACO-14

    Preventive Care and Screening: Influenza Immunization

    68.26

    72.52

    ACO-15

    Pneumonia Vaccination Status for Older Adults

    76.07

    72.92

    ACO-16

    Preventive Care and Screening: Body Mass Index (BMI) Screening and
    Follow-Up

    70.13

    70.69

    ACO-17

    Preventive Care and Screening: Tobacco Use: Screening and Cessation
    Intervention

    96.93

    90.48

    ACO-18

    Preventive Care and Screening: Screening for Clinical Depression and
    Follow-up Plan

    67.16

    61.98

    ACO-19

    Colorectal Cancer Screening

    63.90

    64.58

    ACO-20

    Breast Cancer Screening

    70.71

    70.05

    ACO-42

    Statin Therapy for the Prevention and Treatment of Cardiovascular
    Disease

    82.68

    79.89

    ACO-27

    Diabetes Mellitus: Hemoglobin A1c Poor Control

    20.21

    16.74

    ACO-41

    Diabetes: Eye Exam

    51.54

    50.37

    ACO-28

    Hypertension (HTN): Controlling High Blood Pressure

    71.03

    71.47

    ACO-30

    Ischemic Vascular Disease (IVD): Use of Aspirin or Another
    Antithrombotic

    92.65

    86.86

    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.

    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.
    • 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.