Below are comments from renal organizations and dialysis providers regarding the Centers for Medicare & Medicaid Services' proposed rule for Accountable Care Organizations.

Accountable Kidney Care Collaborative

American Society of Nephrology

DaVita Inc.

Dialysis Patient Citizens

Fresenius Medical Care North America

Kidney Care Partners

National Renal Administrators Association

Renal Physician Association

Renal Support Network 

McGuireWoods LLP has created several analysis of the accountable care organization rules. Here are few that are pertinent to dialysis facilities:

Accountable care organizations: Understanding the two track model
Initially, accountable care organizations can choose to participate in the shared savings program without having to share losses. ACOS that are ready to share losses will benefit from greater savings.

Seven key components to consider on the ACO rules
Under the Medicare Shared Savings Program for Accountable Care Organizations, ACOs meeting certain requirements will be eligible to receive additional payments from Medicare when certain performance guidelines are met and cost-saving targets are achieved.

Accountable Care Organizations: Shared savings calculation
A key component for each ACO participating in the Medicare Shared Savings Program will be Centers for Medicare and Medicaid Services’ determination of the ACO’s expenditure benchmark. In order to determine whether or not an ACO saves the Medicare program money, CMS must set a per capita expenditure benchmark by which to judge any savings or losses the ACO generates for the program.