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Second Opinion

Learn about policy issues important to medical schools and teaching hospitals, with Executive Vice President Atul Grover, M.D., Ph.D.

Washington Highlights

AAMC Submits Comment Letter on Extreme and Uncontrollable Circumstances Rule

February 23, 2018—The AAMC submitted a Feb. 20 comment letter to the Centers for Medicare and Medicaid Service (CMS) supporting the agency’s decision to establish extreme and uncontrollable circumstances policies for the Shared Savings Program that will apply to accountable care organizations (ACOs) impacted by events, such as Hurricanes Harvey, Irma, Maria, and California wildfires.

These catastrophic events that are outside of the ACO’s control likely will result in increased utilization of medical services, higher rates of hospital admissions and longer stays, challenges associated with coordination of care for patients, and many other related issues. The AAMC’s comment letter includes suggestions for policies that could be set forth in the future when disasters occur, such as changes to the calculation of financial performance for the ACOs and methods for assessing quality performance.

The AAMC’s comments emphasize that CMS should address the financial impact of these extreme and uncontrollable circumstances on all Shared Savings Program models (Track 1, Track 1 plus, Track 2, and Track 3) and also stress the importance of considering the impact of these disasters on the baseline for the benchmarks.


Gayle Lee
Director, Regulatory Counsel
Telephone: 202-741-6429


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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806