October 27, 2011

Donald M. Berwick, MD, MPP, Administrator Center for Medicare and Medicaid Services Room 314-G, Hubert H. Humphrey Building 200 Independence Avenue, SW Washington, DC 20210 Re: Medicare Shared Savings Program: Accountable Care Organizations, Final Rule

Dear Don: On behalf of the American Medical Group Association (AMGA), I want to thank you and the Centers for Medicare and Medicaid Services (CMS) for your efforts in drafting the final rule (Final Rule) for the Medicare Shared Savings Program, better known as Accountable Care Organizations (ACOs). Our members have been delivering accountable care before the term existed, some for decades. We believe in the model and want it to succeed. In all the years I have been following rule making, I have never seen a proposed rule change in its final version as much as was the case for ACOsand for the better! Thank you and your many colleagues at CMS for listening to AMGA and for being responsive to the commenting public in general. Naturally, potential ACO participants must evaluate the framework from their unique circumstances, and take into account the concomitantly issued guidance documents from other agencies, those with primary jurisdiction over anti-trust, tax, anti-kickback and related matters. However, it is my impression that you have succeeded in making the ACO regulations workable and attractive enough to garner an initial volume of voluntary participation to get this idea off to a good start. I am certainly recommending to AMGA members that ACOs, in light of the final rule, clearly warrant their serious consideration.

Donald M. Berwick, MD, MPP October 27, 2011 Page Two Please continue to call on me and AMGA members at any time as this important health care delivery reform program comes into being. Sincerely,

Donald W. Fisher, PhD, CAE President and CEO American Medical Group Association cc: Marilyn Tavenner, CMS Principal Deputy Administrator and COO Jonathan Blum, CMS Deputy Administrator and Director, Medicare Management Richard Gilfillan, MD, Acting Director, Center for Medicare and Medicaid Innovation Terri Postma, MD, Medical Officer, CMS