ACO Model Implementation Considerations
There are several important considerations with forming an accountable care organization (ACO) for rural care
Cost: The costs associated with forming an ACO may present challenges for some small
and medium sized rural physician practices that have more limited access to capital and infrastructure.
an ACO may benefit rural providers through shared savings. The shared savings can be reinvested, for example, to
finance care coordination
activities or modernize data infrastructure.
Antitrust laws and minimum beneficiary requirements: These should be considered when forming an
ACO. Because some ACOs participate in both Medicare and commercial markets, the Federal Trade Commission and
Department of Justice developed a policy
statement to guide provider organizations in developing ACOs that comply with federal antitrust laws.
Medicare market: It is important to consider the Medicare market in the rural community. Some
rural ACOs have a
minimum number of Medicare beneficiaries, which may be difficult for frontier communities to maintain. ACOs may
face challenges if providers leave the ACO and, as a result, the number of beneficiaries falls below the
Data sharing: Obtaining permission to share data between healthcare organizations and across
state lines can also be a
challenge for rural ACOs. It is important to establish formal agreements for data sharing.
Resources to Learn More
Provides information and resources regarding the ACO Antitrust Enforcement Policy Statement, including the
Federal Register Notice, a summary of activities following the issuance of the policy, and answers to frequently
Organization(s): Federal Trade Commission
Care Organizations in Rural America
This rural policy brief presents data collected from Medicare ACOs regarding
their presence in metropolitan and non-metropolitan counties.
Organization(s): RUPRI Center for Rural Health Policy Analysis
Hospital Participation in Accountable Care Organizations (ACOs) and Patient-Centered Medical Care
Provides links to a webinar and presentation slides that describe the goals of ACOs, activities conducted by the
Rural Health System Analysis and Technical Assistance projects, and the implementation activities of a rural
Organization(s): National Rural Health Resource Center