Cleveland Clinic Medicare ACO

Medicare Accountable Care Organization (ACO)

What's an ACO?

An ACO is a group of doctors, hospitals, and other health care providers, who come together voluntarily to give coordinated high quality care to the Medicare patients they serve. Coordinated care helps ensure that patients, especially the chronically ill, get the right care at the right time, with the goal of avoiding unnecessary duplication of services and preventing medical errors.

How ACOs work

• Local health care providers and hospitals volunteer to work together to provide you with coordinated care.
• The doctors and other providers who are helping care for
  you will communicate with each other, and partner with you in making health care decisions.
• You may spend less time filling out medical history paper work because your doctors may already have this information in an electronic health record.
• You’ll likely have fewer repeated medical tests because your doctors and hospitals will share information and coordinate your care.
• You’ll be in the center of care, and your doctors will be better able to keep you informed, and to keep listening and honoring your choices.
• Unlike HMOs, managed care, or some insurance plans, an ACO can't tell you which health care providers to see and can't change your Medicare benefits.

How ACOs share information

Cleveland Clinic Medicare ACO doctors will use data from Medicare to help improve how they provide care. For example, your doctors will get your medical information from Medicare to help them to know your medical history, including your medical conditions, prescriptions, and visits to the doctor, and give you the right care at the right time in the right setting. Doctors, hospitals, and other health care providers working together in an ACO are able to read your medical records, along with other office staff authorized to help coordinate your care. The privacy and security of your medical information is protected by federal law. You'll continue to get the same rights enjoyed by all people with Medicare.

Declining to share your health information

Your privacy is very important to us, and you control how your personal information is used.
To help you get the best possible care, Medicare shares information with Cleveland Clinic Medicare ACO about the care their patients get. To prevent Medicare from sharing your personal information with Cleveland Clinic Medicare ACO:

• Call 1.800.MEDICARE (633.4227).
• TTY users should call 1.877.486.2048.

Consent to change your personal health information preference

• Call 1.800.MEDICARE (633.4227).
• TTY users should call 1.877.486.2048.

Cleveland Clinic Medicare ACO contact information

• Call Cleveland Clinic Medicare ACO at 216.445.3666.
• Business hours are Monday – Friday 10 a.m. - 3 p.m.

Where can I find more information about ACOs?

• Visit innovation.cms.gov/innovation-models/aco.
• Visit medicare.gov/acos.
• Call 1.800.MEDICARE (1.800.633.4227) 24 hours a day/7 days a week.
• TTY users should call 1.877.486.2048.
• Information on the Medicare Shared Savings Program.
• Frequently Asked Questions: Accountable Care Organizations & You.

Other resources

• CMS Announces 89 New ACOs.
• In the News: As a New Accountable Care Organization (ACO), Cleveland Clinic Builds on Value-Based Care Efforts.

*Cleveland Clinic Medicare ACO is only for fee-for-service (FFS) Medicare patients and not Medicare Advantage based beneficiaries.

ACO Public Reporting Information

ACO Name and Location

Cleveland Clinic Medicare ACO, LLC
Previous Names: N/A
9500 Euclid Avenue
Mail Code: JJ19
Cleveland, Ohio 44195

ACO Primary Contact

Primary Contact Name	Scott Dynda
Primary Contact Phone Number	216.445.3666
Primary Contact Email Address	ccaco@ccf.org

Organizational Information

ACO Participants

ACO Participants	ACO Participant in Joint Venture (Enter Y or N)
Abrams Eye Center, Inc.	N
Advanced Neurology & EMG, LLC	N
Advanced Women's Health and Surgery, LLC	N
Akron General Medical Center	N
Ara E. Kallibjan	N
Ashtabula County Medical Center	N
Associates in Orthopaedics, Inc.	N
Atrium Medical Group Inc.	N
Atrium Medical Group Mukunda, LLC	N
Atrium Medical Krishnan, LLC	N
Broadview Heights Family Medicine, Inc.	N
Brown Medical Center, Inc.	N
Cardiovascular Consultants of Cleveland, Inc.	N
CCF New York Medical Services, PC	N
CCF Tennessee Medical Services, PC	N
Cleveland Clinic Avon Hospital	N
Cleveland Clinic Children's Hospital for Rehabilitation	N
Cleveland Clinic Home Care	N
Cleveland Clinic Health Services Professional Association, Inc.	N
Cleveland Clinic Health System - East Region	N
Cleveland Clinic Home Care Services	N
Cleveland Clinic Support Services	N
Cleveland Ear Nose Throat Inc.	N
Cleveland Kidney & Hypertension Consultants, Inc.	N
Cleveland Urology Associates, Inc.	N
Clinic Medical Services Company	N
Comprehensive Primary Care, LLC	N
Cosmopolitan Dermatology, Inc.	N
Dayem Health Services, LLC	N
Douglas Web	N
Dr. Miodrag Zivic, LLC	N
Dr. Khalafi, MD, LLC	N
Elite Medical Practice, LLC	N
Fairview Hospital	N
Foot and Ankle Physicians of Geauga, Inc.	N
Great Lakes Hypertension & Kidney Care, Inc.	N
Hassan Alzoubi	N
Hillcrest Mayfield Eye Associates, Inc.	N
Hudson Family Practice, Inc.	N
ID Consultants of Northeast Ohio, Inc.	N
Jeffrey A Chaitoff, MD, LLC	N
Jeffery A Halpert, DPM, LLC	N
Joel D. Weisblat, MD, Inc.	N
Katrina Rakowsky	N
Key Clinics, LLC	N
Kishor Patel, MD, LLC	N
Lake Point Medical Group, LLC	N
Lodi Community Hospital	N
Lutheran Hospital	N
Mark A. Lang, MD, LLC	N
Marymount Hospital, Inc.	N
Med Consults, Inc.	N
Medina Hospital	N
Mercy Medical Center	N
Mercy Professional Care, LLC	N
Michael Kalus	N
Mila Davidovic	N
Mohan J Durve, MD, Inc.	N
Montrose Sleep Center, LLC	N
N Presswala	N
North Shore Gastroenterology, Inc.	N
Northcoast Dermatology Associates, Inc.	N
Northcoast Foot and Ankle Associates, Inc.	N
Northern Ohio Internal Medicine Associates, Inc	N
OBGYN of Westlake, LLC	N
Ori Kushnir MD OBGYN, LLC	N
Partners Physician Group	N
Prestige Foot & Ankle Center, LLC	N
Randal March	N
Retina Associates of Cleveland, Inc.	N
Richard Koletsky	N
Ronald A Freireich, DPM	N
Ronald Golovan, MD, Inc.	N
Signature Meds, LLC	N
Signature Psychiatry Associates, Inc.	N
Stephen Musser DPM, Inc.	N
Ted Peterson, DPM	N
The Cleveland Clinic Foundation	N
Thomas Slawinski	N
Tim Nice MD, Inc.	N
Timothy Levar, DPM, LLC	N
Union Physician Services, LLC.	N
Vijay G. Mistry, MD, Inc.	N
Vyacheslav Isakov	N
Wooster Clinic, LLC	N
Yael Dinar Kushnir, MD	N

ACO Governing Body

Member First Name	Member Last Name	Member Title/Position	Member's Voting Power (Expressed as a percentage)*	Membership Type	ACO Participant Legal Business Name and D/B/A, if applicable
Christopher	Babiuch	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
John	Bertsch	Physician	5.882	ACO Participant Representative; Voting Member	New Family Physicians Associates, Inc.
Kenneth	Braman	Physician	5.882	ACO Participant Representative; Voting Member	Partners Physician Group
David	Burrier	Physician	5.882	ACO Participant Representative; Voting Member	Union Physician Services
Timothy	Crone	Physician	5.882	ACO Participant Representative; Voting Member	Mercy Medical Center
Teresa	Dews	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Tom	Gable	N/A	5.882	Medicare Beneficiary Representative and Community Stakeholder Representative; Voting Member	N/A
Jessica	Hohman	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Lew	Hutchison	Administration	5.882	ACO Participant Representative; Voting Member	Ashtabula County Medical Center
Robert	Jones	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Leslie	Jurecko	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Mark	Malloy	Administration	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Michelle	Medina	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Stephen	Meldon	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Maged	Rizk	Physician	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Bruce	Rogen	Administration	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation
Wes	Wolfe	Administration	5.882	ACO Participant Representative; Voting Member	The Cleveland Clinic Foundation

*Due to rounding, ‘Member’s Voting Power’ may not equal 100 percent.

Key ACO Clinical and Administrative Leadership

Interim Chair, Board of Managers	Michelle Medina, MD
President & Medical Director; ACO Executive	Jessica Hohman, MD
Associate Medical Director; Quality Assurance / Improvement Officer	Maged Rizk, MD
Chief Financial Officer & Treasurer	Dennis Laraway
Chief Legal Officer & Secretary	David Rowan
Chief Compliance Officer	Emily Williams

Associated Committees and Committee Leadership

Committee Name	Committee Leader Name and Position
Executive Committee	Jessica Hohman, MD, Chair
Finance Committee	Mark Malloy, Chair
Performance Optimization Committee	Maged Rizk, MD, Chair
Compliance Committee	Kenneth Braman, DO, Chair

Types of ACO participants, or combinations of participants, that formed the ACO

• ACO professionals in a group practice arrangement
• Networks of individual practices of ACO professionals
• Hospital employing ACO professionals

Shared Savings and Losses

Amount of Shared Savings/Losses

• Third Agreement Period
  • Performance Year 2022, $15,575,099
• Second Agreement Period
  • Performance Year 2021, N/A
  • Performance Year 2020, $9,556,622.94
  • Performance Year 2019, N/A
  • Performance Year 2018, N/A
• First Agreement Period
  • Performance Year 2017, N/A
  • Performance Year 2016, $19,914,592
  • Performance Year 2015, $16,614,051

Shared Savings Distribution

• Third Agreement Period
  • Performance Year 2022
    • Proportion invested in infrastructure: 10%
    • Proportion invested in redesigned care processes/resources: 15%
    • Proportion of distribution to ACO participants: 75%
• Second Agreement Period
  • Performance Year 2021
    • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A
  • Performance Year 2020
    • Proportion invested in infrastructure: 15%
    • Proportion invested in redesigned care processes/resources: 10%
    • Proportion of distribution to ACO participants: 75%
  • Performance Year 2019
    • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A
  • Performance Year 2018
    • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A
• First Agreement Period
  • Performance Year 2017
    • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A
  • Performance Year 2016
    • Proportion invested in infrastructure: 5%
    • Proportion invested in redesigned care processes/resources: 5%
    • Proportion of distribution to ACO participants: 90%
  • Performance Year 2015
    • Proportion invested in infrastructure: 5%
    • Proportion invested in redesigned care processes/resources: 5%
    • Proportion of distribution to ACO participants: 90%

2022 Quality Performance Results

Quality Performance results are based on CMS Web Interface

Measure Number	Measure Name	Collection Type	Rate	ACO Mean
001	Diabetes: Hemoglobin A1c (HbA1c) Poor Control	CMS Web Interface	5.18	10.71
134	Preventative Care and Screening: Screening for Depression and Follow-up Plan	CMS Web Interface	72.22	76.97
236	Controlling High Blood Pressure	CMS Web Interface	73.02	76.16
318	Falls: Screening for Future Fall Risk	CMS Web Interface	98.29	87.83
110	Preventative Care and Screening: Influenza Immunization	CMS Web Interface	84.30	77.34
226	Preventative Care and Screening: Tobacco Use: Screening and Cessation Intervention	CMS Web Interface	100.00	79.27
113	Colorectal Cancer Screening	CMS Web Interface	85.87	75.32
112	Breast Cancer Screening	CMS Web Interface	89.69	78.07
438	Statin Therapy for the Prevention and Treatment of Cardiovascular Disease	CMS Web Interface	91.10	86.37
370	Depression Remission at Twelve Months	CMS Web Interface	11.46	16.03
479	Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Groups [Risk Standardized, All Condition Readmission]*	Administrative Claims	0.1533	0.1510
484	Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions	Administrative Claims	34.83	30.97
CAHPS-1	CAHPS: Getting Timely Care, Appointments, and Information	CAHPS for MIPS Survey	77.74	83.96
CAHPS-2	CAHPS: How Well Your Providers Communicate	CAHPS for MIPS Survey	90.77	93.47
CAHPS-3	CAHPS: Patients’ Rating of Provider	CAHPS for MIPS Survey	90.05	92.06
CAHPS-4	CAHPS: Access to Specialists	CAHPS for MIPS Survey	71.28	77.00
CAHPS-5	CAHPS: Health Promotion and Education	CAHPS for MIPS Survey	63.25	62.68
CAHPS-6	CAHPS: Shared Decision Making	CAHPS for MIPS Survey	50.37	60.97
CAHPS-7	CAHPS: Health Status and Functional Status	CAHPS for MIPS Survey	72.71	73.06
CAHPS-8	Care Coordination	CAHPS for MIPS Survey	82.15	85.46
CAHPS-9	Courteous and Helpful Office Staff	CAHPS for MIPS Survey	90.62	91.97
CAHPS-11	CAHPS: Stewardship of Patient Resources	CAHPS for MIPS Survey	27.20	25.62

For previous years’ Financial and Quality Performance Results, please visit: data.cms.gov.

Please note: In the Quality Performance Results file(s) above, search for “Cleveland Clinic Medicare ACO, LLC” to view the quality performance results. This ACO can also be found by using the ACO ID A2729 in the public use files on data.cms.gov.

Payment Rule Waivers

• Skilled Nursing Facility (SNF) 3-Day Rule Waiver:
  • Our ACO uses the SNF 3-Day Rule Waiver, pursuant to 42 CFR § 425.612.
• Waiver for Payment for Telehealth Services:
  • Our ACO clinicians provide telehealth services using the flexibilities under 42 CFR § 425.612(f) and 42 CFR § 425.613.

ACO Participation Waivers

The following information describes each arrangement for which our ACO seeks protection under the ACO Participation Waiver, including any material amendment or modification to a disclosed arrangement.

Epic Platform

Parties to the arrangement:

• Cleveland Clinic Medicare ACO, LLC and eligible physicians.
• Eligible Physicians include physicians participating in CCF ACO, and other physicians who: (i) serve a population that includes Medicare beneficiaries; (ii) demonstrate alignment with “the triple aim” by serving on a sub-committee of the CCF ACO or working toward the achievement of identified metrics that are complimentary to those of CCF ACO; (iii) have privileges at any CCF hospital; and (iv) satisfy any other eligibility requirements to be established by the CCF ACO.

Date of arrangement:

• 12/14/2017 is the date of Board Approval; this waiver continues to be in effect.

Items, services, goods, or facility provided:

• An annual license to the Epic Systems electronic health records platform and, in some cases, a one-time activation fee, as well as the Clinovations health information technology product.

Date and nature of any amendments to the arrangement, if applicable.

• N/A. A typographical error was corrected on 3/16/2023.

Description and Board Authorization:

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 a waiver 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 waiver, the governing body of the Cleveland Clinic Medicare ACO, LLC (“CCF ACO”) has made a bona fide, detailed determination that the following arrangement is reasonably related to the purposes of the MSSP.

The CCF ACO proposes to provide, at no cost, an annual license to the Epic Systems electronic health records platform (the “Epic Platform”) to enable use of the Epic Platform (the “Proposed Epic License Program”), to certain physicians (“Eligible Physicians”), some of whom already have a license to use the Epic Platform and some of whom do not. For those Eligible Physicians who do not already have a license to use the Epic Platform, CCF ACO will also pay a one-time activation fee. Eligible Physicians will include physicians participating in CCF ACO, and other physicians who: (i) serve a population that includes Medicare beneficiaries; (ii) demonstrate alignment with “the triple aim” by serving on a sub-committee of the CCF ACO or working toward the achievement of identified metrics that are complimentary to those of CCF ACO; (iii) have privileges at any CCF hospital; and (iv) satisfy any other eligibility requirements to be established by the CCF ACO.

The governing body of CCF ACO approved the Proposed Epic License Program following a determination that the Proposed Epic License Program would support the purposes of the MSSP by managing and coordinating care for beneficiaries through the CCF ACO, encouraging investment in infrastructure for high quality and efficient service delivery for patients, providing enabling technology to monitor patients and access patient medical records, evaluating health needs of CCF ACO’s assigned population, and allowing for the potential for more efficient decision-making.

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 Cleveland Clinic Medicare ACO, LLC, an Ohio nonprofit limited liability company (the “Company”) has made a bona fide, detailed determination that the following arrangement is reasonably related to the purposes of the MSSP.

In order to receive the benefit of such waivers, the governing body of Cleveland Clinic Medicare ACO, LLC, an Ohio nonprofit limited liability company (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 Cleveland Clinic Foundation bears the full costs associated with the implementation of the Clinovations health information technology product for independent primary care providers, most of whom are participants in the Company but all of whom treat Medicare beneficiaries attributed to the Company (the “Arrangement”). 

The governing body of the Company authorized the application of the waiver to the Arrangement on December 14, 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) provides enabling technology to gain greater and more comprehensive access to patient information, which allows for the delivery of higher quality healthcare services to Medicare beneficiaries attributed to the Company; (ii) is targeted toward use for the Medicare-eligible patient population; (iii) encourages investment in infrastructure for high quality and efficient service delivery for Medicare beneficiaries attributed to the Company and maximizes the efficiency of the EpicCare Ambulatory platform; (iv) assists in managing and coordinating care for Medicare beneficiaries attributed to the Company; and (v) assists in evaluating the health needs of the Company’s assigned population.

PAC Investment

Parties to the arrangement:

• Cleveland Clinic Medicare ACO (CCMACO), LLC, and
• Cleveland Clinic Foundation, d/b/a Cleveland Clinic (“CCF”).

Date of arrangement:

• 3/10/2022 is the date of Board Approval; this waiver continues to be in effect.

Items, services, goods, or facility provided:

• An annual allocation of funds to the ACO for the purpose of a “PAC Investment,” i.e., covering the cost of salaries of professional individuals and a software license for enhanced post-acute care management and care coordination, as well as expenses related to quality reporting. The funds come from CCF’s participation in the PCF Model, a CMMI model.

Date and nature of any amendments to the arrangement, if applicable:

• Not applicable.

Description and Board Authorization:

CCMACO desires to implement a program designed to serve the post-acute and transitional care needs of its Medicare beneficiaries through, among other things, providing care coordination and navigation, advance care planning, transitional care management, patient support during and following discharge from a skilled nursing facility, and real-time patient tracking and management throughout the continuum of care (collectively, the “PAC Investment”). In connection with the PAC Investment, CCMACO will employ approximately 10 full-time professionals (the “PAC Team”) and obtain a license for certain software to facilitate the work of the PAC Team and ACO system teams, as well as cover expenses related to quality reporting. CCMACO proposes to utilize revenue from Cleveland Clinic Foundation’s participation in the Primary Care First (“PCF”) program to fund the PAC Investment.

The governing body of CCMACO authorized the application of the waiver to the PAC Investment on March 10, 2022, following a determination that the PAC Investment supports the goals of CCF ACO and is reasonably related to the purposes of the MSSP, in each case because:

• The PAC Investment is designed to enhance care coordination and reduce the need for avoidable acute care through, among other things, advance care planning during transitions of care and patient support following discharge from a skilled nursing facility. Addressing this historically inefficient, opaque, and costly process for patients transitioning of institutional PAC facilities improves efficiency and quality and assists in lowering the total cost of care.
• The PAC Investment is designed to create investment in necessary information technology software to assist in effective and meaningful care coordination among providers and help ensure realization of community resources and escalation pathways.
• The PAC Investment will help ACO Participants provide enhanced care coordination and design more efficient care processes for patients, including for Medicare beneficiaries attributed to the Company, through access to the Company’s dedicated post-acute care team of professionals.
• Using funds earned through PCF to enhance ACO care coordination helps align the financial incentives for ACO Participants to support investment in more efficient care processes, especially because of the similarities in goals, management, and patient populations of CCF’s PCF program and the Company’s ACO.

Pharmacy Investment

Parties to the arrangement:

• Cleveland Clinic Medicare ACO (CCMACO), LLC, and
• Cleveland Clinic Foundation, d/b/a Cleveland Clinic (CCF)

Date of arrangement:

• 6/9/2022 is the date of Board Approval; this waiver continues to be in effect.

Items, services, goods, or facility provided:

• An annual allocation of funds to the ACO for the purpose of a “Pharmacy Investment,” i.e., covering the cost of salaries of two pharmacists. The funds come from CCF’s participation in the PCF Model, a CMMI model.

Date and nature of any amendments to the arrangement, if applicable:

• Not applicable.

Description and Board Authorization:

CCMACO desires to implement a program designed to serve the needs of its Medicare beneficiaries through, among other things, a program to improve access, quality, coordination, and evidence-based care for ACO patients in need of prescribed pharmacologic therapies and disease education (collectively, the “Pharmacy Investment”). In connection with the Pharmacy Investment, CCMACO will employ approximately two full-time pharmacists (the “Pharmacists”). CCMACO proposes to utilize revenue from Cleveland Clinic Foundation’s participation in the Primary Care First (“PCF”) program to fund the Pharmacy Investment.

The governing body of CCMACO authorized the application of the waiver to the Pharmacy Investment on June 9, 2022, following a determination that the Pharmacy Investment supports the goals of CCMACO and is reasonably related to the purposes of the MSSP, in each case because:

• The Pharmacy Investment is designed to promote accountability for the quality and cost of care by building institutional resources to promote informed choices by prescribers and patients.
• The Pharmacy Investment is designed to improve management and coordination of care by addressing, e.g., barriers to medication adherence, risks of drug interactions and poly-pharmacy, drug affordability challenges, and lack of information about medically effective drug substitutions.
• The Pharmacy Investment is an investment in infrastructure and redesign of care processes for high-quality and efficient service delivery, such as promoting optimal site of service for drug administration and the use of “adherence packaging” for medications, as well as broader initiatives designed to improve evidence-based medication management of diabetes, hypertension, heart failure, COPD, and chronic kidney disease.
• Using funds earned through PCF to enhance ACO care coordination helps align the financial incentives for ACO Participants to support investment in more efficient care processes, especially because of the similarities in goals, management, and patient populations of CCF’s PCF program and the CCMACO.