The Commonwealth ACO, LLC Board of Managers has formally approved the following arrangements as reasonably related to the purposes of the Medicare Shared Savings Program, as required for the MSSP ACO Participation Waiver.
Gentiva Home Health (Kindred at Home; Hospice Family Care Inc. Central Arizona Home Health; and subsidiaries.)
Participant Agreement with Gentiva Home Health. Commonwealth has entered into an ACO Participant Agreement dated on or about March 1, 2014 (“Participant Agreement”) with Gentiva, to further the purposes of the Medicare Shared Savings Program by assisting Commonwealth to improve process, protocol and communications related to home health. The arrangement between Commonwealth and Gentiva is reasonably related to the purposes of the MSSP, because these arrangements: (i) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company by encouraging the development of a transitional care program and a network of home care providers; (ii) encourage the management and coordination of care for patients of the Company through the provision of nurse managers and post acute care services, and (iii) encourages Gentiva to invest in the infrastructure and transitional care processes for the Company to deliver high quality and efficient services to the population it serves.
AzTech Radiology, Inc
Participant Agreement with AzTech Radiology, Inc. (AzTech). Commonwealth has entered into an ACO Participant Agreement dated on or about June 1, 2018 (“Participant Agreement”) with AzTech, to further the purposes of the Medicare Shared Savings Program by assisting Commonwealth to improve process, protocol and communications related to radiology services. The arrangement between Commonwealth and AzTech are reasonably related to the purposes of the MSSP, because these arrangements: (i) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company by fostering communication and education between the primary care physicians and to create a network of radiology providers; (ii) manage and coordinate care for Medicare beneficiaries through the Company by coordination of care, preventative screening, quality metric screening and potential of programs for new service offerings such as MSK ultrasound and; (iii) encourage AzTech to invest in the infrastructure and processes for the Company to deliver high quality and efficient services to the population it serves.
Premier Medical Group, LLC
Commonwealth has entered into an agreement, on or about May 17, 2016, to help support the creation of a single tax id primary care group, Premier Medical Group LLC. Commonwealth and Premier will further the purposes of the Medicare Shared Savings Program to promote accountability for the quality, cost and overall care for populations served by the ACO by forming a large primary care practice that better aligns physicians and improves the management and coordination of care and better promotes the development of redesigned care processes to promote high quality and efficient service delivery for ACO’s patients.
EMR Support for Participating Primary Care Practices
Commonwealth has entered into an agreement, dated on or about December 1, 2016, with its participating primary care practices to help support the migration to a more consolidated electronic medical record (EMR) platform. This program supported by Commonwealth will further the purposes of the Medicare Shared Savings Program to promote greater access and accountability for the quality, cost and overall care for populations served by the ACO by forming a more consolidated EMR platform that supports Medicare initiatives, especially promoting the advancement of required activities under MACRA and MIPS requirements for 2017 and beyond. This effort to consolidate EMRs better aligns physicians with ACO initiatives and improves the management and coordination of care and better promotes the development of consistent use of quality and care processes to promote high quality and efficient service delivery for ACO’s patients.
Premier Medical Group LLC
Participant Agreement with Premier Medical Group (PMG). Commonwealth and its wholly owned subsidiary, Arizona Physician’s Lab have entered into an ACO Participant Agreement dated on or about February 20, 2018 (“Participant Agreement”). the arrangements between the Company and PMG described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) invest in the infrastructure and processes for the Company, in particular, purchase and or leasing of assets related to lab operations to improve patient care and outcomes to the population it serves; (ii) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through the use of quality incentive payments and distributions to providers for lab specific quality metrics, efficiency and in network use of lab testing; (iii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to care coordination through dedicated lab quality and lab operating committees;
Sonora Quest Laboratories LLC
Participant Agreement with Sonora Quest Laboratories LLC (Sonora Quest). Commonwealth has entered into an ACO Participant Agreement dated on or about May 1, 2017 (“Participant Agreement”). the arrangements between the Company and Sonora Quest described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through the use of Sonora Quests proprietary Actionable Insights Management tool, by education and instruction to the primary care physicians and to create a sustainable network; (ii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to care coordination; (iii) invest in the infrastructure and processes for the Company to improve patient care and outcomes to the population it serves.
Third Party Laboratory Interface Support for Participating Primary Care Practices
Commonwealth has entered into an agreement with its ACO practices on our about April 1, 2018 to help support the migration to a more consolidated laboratory order and results interface platform. The agreement is with a third-party vendor, in conjunction with the practice’s current Electronic Medical Record (EMR) platform to assist ACO practices in lab interface, integrations, templating and workflow. This arrangement; (i) promotes accountability for the quality, cost and overall care for the Medicare population that is managed by the Company and supports the infrastructure for the ACO by enabling the ACO to migrate to more consistent use or partnered clinical labs which will better position the ACO, over the course of time, to promote a standard primary care workflow for lab testing; (ii) translates to more uniform practice patterns which will be based on template-driven evidence based medicine; and (iii) facilitates a consolidated lab ordering and results interface in place at the ACO will improve the coordination of care and patient management and will assist in more consistent adherence to care processes established by the ACO.
Summit Therapy Group LLC
Participant Agreement with Summit Therapy Group (Summit). Commonwealth has entered into an ACO Participant Agreement with a start date on or about April 1, 2018 (“Participant Agreement”). the arrangements between the Company and Summit described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) invest in the infrastructure and processes for the Company, in particular, hospice and palliative care operations to improve patient care and outcomes to the population it serves; (ii) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through the efficient use of hospice services and the reduction of unnecessary hospital admissions and readmissions; (iii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to care coordination through dedicated quality and operating committees.
Vitalab INC. dba Vasco Infusion
Participant Agreement with Vitalab Inc (Vasco). Commonwealth has entered into an ACO Participant Agreement with a start date on or about December 2018 (“Participant Agreement”) to further the purposes of the Medicare Shared Savings Program (“MSSP”) by providing the Company with the following: (i) financial support to assist the Company in funding its infrastructure and (ii) services to the Company in the form of outpatient infusion services (especially for reduction of cellulitis and urinary tract infection) as well as education, training of use and related support services.
VibrantCare Outpatient Rehabilitation West, Inc.
Participant Agreement with VibrantCare Outpatient Rehabilitation West, Inc. Commonwealth has entered into an ACO Participant Agreement with a start date on or about December 2018 (“Participant Agreement”) with VibrantCare Outpatient Rehabilitation West, Inc. (“Vibrant”), to further the purposes of the Medicare Shared Savings Program (“MSSP”) by providing the Company with the following: (i) provide a network of physical therapy and rehabilitation providers; and (ii) financial support to assist the Company in funding its infrastructure and expenses; and (iii) services to the Company in the form of physical therapy and rehabilitative related reporting, support and educational services.
Desert Kidney Associates
Affiliate Agreement with Desert Kidney Associates. Commonwealth has entered into an ACO Participant Agreement with a start date on or about January 2018 (“Participant Agreement”) with Desert Kidney Associates (DKA), to further the purposes of the Medicare Shared Savings Program (“MSSP”) by providing the Company with the following: (i) provide a network of nephrology providers; and (ii) financial support to assist the Company in funding its infrastructure and expenses; and (iii) services to the Company, its beneficiaries and providers in the form of nephrology related reporting, support and educational services with the purpose to identify members at risk for and prevent early onset of chronic kidney conditions such as end stage renal disease.
Hospice Family Care, Inc. and Central Arizona Home Health Care, Inc.
Participant Agreement with Hospice Family Care, Inc. and Central Arizona Home Health Care, Inc. (Kindred/Curo Hospice). Commonwealth has entered into an ACO Participant Agreement with a start date on or about January, 2019 (“Participant Agreement”). The arrangements between the Company and Kindred/Curo Hospice described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) invest in the infrastructure and processes for the Company, in particular, hospice and the more integrated coordination between hospice, palliative care and home health operations to improve patient care and outcomes to the population it serves; (ii) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through developing a plan for more efficient transitions in care that better coordinates admissions and discharge planning with home care and hospice; (iii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to transitions of care through dedicated quality and operating committees.
Newstar Medical Laboratories, LLC
Participant Agreement with Newstar Medical Laboratories, LLC (Newstar). Commonwealth has entered into an ACO Participant Agreement dated on or about July 1, 2019, pursuant to which Newstar has agreed to become a participating affiliate of the Company and to provide certain services in furtherance of the Company’s ACO activities, including a proprietary program to support the ongoing management of patients that may be appropriate for chronic care management or that have multiple medications. The Board of Managers has determined that the arrangements between the Company and Newstar described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through more effective monitoring more efficient use of medication management. The Company and Newstar will be monitoring potential prescription or over the counter contraindications, reduction of unnecessary emergency room visits and adverse events related to medication such as hospital admissions and readmissions; (ii) invest in the infrastructure and processes for the Company, in particular, prescription and over the counter medication management and monitoring to improve patient care and outcomes to the population it serves; (iii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to prescription and over the counter medication management and monitoring through dedicated quality and operating committees and other resources.
Participant Agreement with Heart & Rhythm Solutions, LLC (HRS). Commonwealth has entered into an ACO Participant Agreement dated on or about April 16, 2020, pursuant to which HRS has agreed to become a participating affiliate of the Company and to provide certain cardiology related services (such as electrophysiology and other non invasive cardiology services) in furtherance of the Company’s ACO activities. The Board of Managers has determined that the arrangements between the Company and HRS described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through identification of high risk cardiology patients, expanding preventative testing programs for cardiology related conditions and the reduction of unnecessary emergency room visits and hospital admissions and readmissions; (ii) invest in the infrastructure and processes for the Company, in particular, identification of high risk cardiology conditions to improve patient care and outcomes to the population it serves; (iii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to non invasive and preventative cardiology care through dedicated quality reporting, patient follow up and other resources.
Participant Agreement with Arizona Cardiovascular Care. Commonwealth has entered into an ACO Participant Agreement dated on or about June 16, 2020, pursuant to which Arizona Cardiovascular Care has agreed to become a participating affiliate of the Company and to provide certain cardiology related services (especially related to interventional cardiology) in furtherance of the Company’s ACO activities. The Board of Managers has determined that the arrangements between the Company and HRS described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) Work with ACO and offices in assisting to identifying at-risk patients with cardiology related health conditions or that meet related medical necessity and may be at risk for inpatient or outpatient interventional procedures. (ii) Assist ACO offices with infrastructure and expenses related to the proper education and delivery of the appropriate cardiology related screening programs. (iii) manage and coordinate care for Medicare beneficiaries through the Company by improving communication and information related to potentially interventional cardiology through dedicated quality and operating committees and other resources.
Participant Agreement with East Valley Gastroenterology and Hepatology Associates PC (EVGastro). Commonwealth has entered into an ACO Participant Agreement dated on or about April 1, 2021, pursuant to which EVGastro has agreed to become a participating affiliate of the Company and to provide certain cardiology related services in furtherance of the Company’s ACO activities. The Board of Managers has determined that the arrangements between the Company and EVGastro described herein and stated in the Agreement are reasonably related to the purposes of the MSSP, because these arrangements: (i) Support the Company in the form of helping to fund infrastructure and expenses (ii) promote the accountability for the quality, cost and overall care for the Medicare population that is managed by the Company through identification of patients in need of colorectal screening and related quality metrics; (iii) additional outpatient or preventative services in related to gastric conditions.