October 27, 2011Donald M. Berwick, MD, MPP, Administrator Center for Medicare and Medicaid ServicesRoom 314-G, Hubert H. Humphrey Building200 Independence Avenue, SWWashington, DC 20210Re: Medicare Shared Savings Program: Accountable Care Organizations,Final RuleDear Don:On behalf of the American Medical Group Association (AMGA), I want to thank youand the Centers for Medicare and Medicaid Services (CMS) for your efforts indrafting the final rule (Final Rule) for the Medicare Shared Savings Program, better known as Accountable Care Organizations (ACOs). Our members have beendelivering “accountable care” before the term existed, some for decades. Webelieve in the model and want it to succeed.In all the years I have been following rule making, I have never seen a proposedrule change in its final version as much as was the case for ACOs—and for thebetter! 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 uniquecircumstances, and take into account the concomitantly issued guidance documentsfrom other agencies, those with primary jurisdiction over anti-trust, tax, anti-kickbackand related matters. However, it is my impression that you have succeeded inmaking the ACO regulations workable and attractive enough to garner an initialvolume of voluntary participation to get this idea off to a good start. I am certainlyrecommending to AMGA members that ACOs, in light of the final rule, clearlywarrant their serious consideration.