Letter to CMS and HHS on behalf of Florida ACOs

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US Department of Health & Human Services Centers for Medicare & Medicaid Services

RE: Coronavirus Pandemic – Florida ACO Response

The Florida Association of ACOs is the premier professional organization for accountable care organizations and value-based healthcare leaders throughout Florida. We bring together the organizations that drive providers to work together to increase the quality of care delivered to patients while significantly lowering medical costs overall. Driven by shared savings payment arrangements developed by both government and private sector payers, we are witnessing as well as driving the fast and successful growth of value-based models in the State of Florida.

We are in unprecedented times with the onset of the COVID-19 Pandemic and never before have we had the opportunity to see the impact of ACOs in our communities in their ability to help providers respond to this pandemic in a way that is compassionate, organized and supported. ACOs, by their mission, are built to help providers deliver quality, patient centric and cost-effective care. Providing access is also at the core of their mission. I am pleased to share that ACOs in the State of Florida have risen to the opportunity of this crisis and have mobilized to execute on these critical goals in an extraordinary fashion. Our ACO leaders are maximizing the use of telemedicine and OIG enforcement waivers in order to react to the needs of our beneficiaries. ACO’s are working together to network best practices and are delivering infrastructure to support continuous care via telehealth, and care management to our chronically ill and directly affected patients. Many providers were struggling with what to do amidst this crisis and without this support would have closed.

The purpose of this letter is to thank CMS and HHS for their prompt response to this crisis by eliminating barriers to care. We profusely applaud the pervasive changes to telehealth and OIG enforcement waivers and cannot overstate how profound of a positive impact it has made to our providers and the patients that they care for. Finally, we would like to commend CMS for your unwavering commitment to value-based care and to ACOs through the MSSP and other CMMI programs. Absent these programs there wouldn’t be the incentive or infrastructure to manage this crisis as well as our Florida ACOs are doing.

With all of our focus on managing this crisis, we have found the administrative work of some program requirements is competing with mission critical patient safety initiatives. We are very appreciative of today’s ACO reporting and MIPs reporting deadline delays but additionally request that the deadlines for program applications be extended as well. We are hopeful these will include any contracts that are expiring as well as recruiting deadlines to add new participants.

Thank you again for the opportunity to make a difference for our beneficiaries, providers and country. We hope these extreme times and the ACO driven positive outcomes reinforce the need for similar and more value-based models moving forward.


Nicole Bradberry


Florida Association of ACOs