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Position Paper Offers Recommendations on Addressing Health Equity
NAACOS Advocates for Additional Policies to Support ACOs’ Efforts

WASHINGTON — The National Association of ACOs (NAACOS) today published a position paper that outlines several policy recommendations to better position ACOs to address health inequities and social determinants of health (SDOH). The paper and its recommendations are the result of a working group of leading ACOs across the country. 

Alternative payment models that make providers accountable for patients’ total cost of care, such as ACOs, are incentivized to address patient needs so that long-term health is improved. During the ongoing COVID-19 pandemic, which has highlighted deeply embedded inequities in our healthcare system, ACOs have deployed several strategies to address those disparities, as the white paper points out. However, ACOs need additional tools, data, financial incentives, and resources to improve health equity and develop partnerships with community-based organizations (CBOs). 

“ACOs are already beginning to do the work of addressing SDOH to improve quality and control costs for the patients they serve. However, they cannot be broadly effective or achieve desired outcomes without proper funding and support,” the report states. “The implementation of these recommendations will help to ensure that ACOs are equipped to effectively measure, track, and improve health equity in their work.” 

Among the recommendations made are:

  • Providing ACOs with both grant money and adjusted benchmarks to support the work of addressing health equity. This includes providing financial support to expand social services and offering higher benchmarks, or CMS-set spending targets ACOs must meet to share savings with CMS, to benefit ACOs treating vulnerable populations.
  • Adopting the Center for Medicare and Medicaid Innovation’s model that provides ACOs with upfront money to support ACO formation in rural areas to cover urban areas that meet the definition of a distressed community. The Community Health and Rural Transformation (CHART) Model was placed on hold and is expected to begin accepting applications in Spring 2022.
  • Providing additional flexibility with Medicare rules for ACOs to deliver supplemental benefits to patients to help address health equity. Some examples of supplemental benefits that may be offered include transportation support, food, pest control, indoor air quality equipment, structural home modifications, and others.
  • Ensuring quality reporting requirements are thoughtfully designed to further target quality improvement efforts for populations struggling with health inequities. Tying performance to all patients, as the Centers for Medicare & Medicaid Services is moving towards, incentivizes providers to avoid high-risk, traditionally underserved patients.
  • Improving ACOs’ access to data needed for care coordination. ACOs should have access to substance use disorder (SUD) claims data to providers practicing in ACOs to help support their work in population health management and SUD-focused initiatives. 

“ACOs are already beginning to address negative SDOH and close health equity gaps, but they cannot be broadly effective or achieve their goals without proper funding and support,” said Clif Gaus, Sc.D., NAACOS president and CEO. “CMS and Congress should work through ACOs to improve inequities and address social determinants. The implementation of these recommendations will ensure that all ACOs are equipped to advance health equity in their work while improving quality of care and controlling costs.” 

The paper is being published in conjunction with the NAACOS Fall 2021 Conference, and health equity is a focal point of several conference sessions. 



David Pittman
NAACOS Senior Policy Advisor
202-640-2689 or [email protected]