MSSP ACO

ACO Name and Location

Piedmont Clinic ACO LLC

Previous Names: N/A
271 17th Street NW
Atlanta, Georgia 30363

ACO Primary Contact

Primary Contact Name: Patrick Edlin
Primary Contact Phone Number: 470-725-1749
Primary Contact Email Address: patrick.edlin@piedmont.org

ACO PARTICIPANTS:

ACO GOVERNING BODY

ADDITIONAL ACO INFORMATION

Key ACO Clinical and Administrative Leadership:

Associated Committees and Committee Leadership:

Types of ACO participants, or combinations of participants, that formed the ACO:

Network of individual practices of ACO Professionals

SHARED SAVINGS AND LOSSES

Amount of Shared Savings/Losses

• Third Agreement Period
  • Performance Year 2025, N/A
• Second Agreement Period
  • Performance Year 2024, $24,357,900
  • Performance Year 2023, $19,204,145
  • Performance Year 2022, $15,400,718
  • Performance Year 2021, $15,664,221
  • Performance Year 2020, $15,015,308

• First Agreement Period
  • Performance Year 2019, $15,190,478
  • Performance Year 2018, $0
  • Performance Year 2017, $0

Shared Savings Distribution

• Third Agreement Period
  • Performance Year 2025
    • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A
• Second Agreement Period
  • Performance Year 2024
    • Proportion invested in infrastructure: $13,857,000 / 57%
    • Proportion invested in redesigned care processes/resources: TBD
    • Proportion of distribution to ACO participants: $10,500,000 / 43%
  • Performance Year 2023
    • Proportion invested in infrastructure: $7,032,440 / 37%
    • Proportion invested in redesigned care processes/resources: TBD
    • Proportion of distribution to ACO participants: $12,171,705 / 63%
  • Performance Year 2022
    • Proportion invested in infrastructure: $4,930,636 / 33%
    • Proportion invested in redesigned care processes/resources: TBD
    • Proportion of distribution to ACO participants: $10,162,068 / 67%
  • Performance Year 2021
    • Proportion invested in infrastructure: $5,220,525 / 33%
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: $10,443,696 / 67%
  • Performance Year 2020
    • Proportion invested in infrastructure: $6,000,000 / 40%
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: $9,015,308 / 60%

• First Agreement Period
  • Performance Year 2017
  • • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A
  • Performance Year 2018
  • • Proportion invested in infrastructure: N/A
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: N/A

• • Performance Year 2019
    • Proportion invested in infrastructure: $7,000,000 / 46%
    • Proportion invested in redesigned care processes/resources: N/A
    • Proportion of distribution to ACO participants: $8,190,478 / 54%

2024 Quality Performance Results:

[1] A lower performance rate corresponds to higher quality.

[2] For PY 2024, the CMS Web Interface measures Quality ID #438 and Quality ID #370 do not have benchmarks, and therefore, were not scored.

[3] CAHPS for MIPS is a composite measure, so numerator, denominator, and performance rate values are not applicable (N/A). The CAHPS for MIPS composite score is calculated as the average number of points across scored Summary Survey Measures (SSMs) (86 FR 65256). Refer to Table 5 for details on CAHPS for MIPS performance.

PAYMENT RULE WAIVERS

• Waiver for Payment for Telehealth Services:
  • Yes, our ACO clinicians do provide telehealth services using the flexibilities under 42 CFR 425.612(f) and 42 CFR 425.613.

FRAUD AND ABUSE WAIVERS

• ACO Participation Waiver (Kyruus + DexCare): the following information describes each arrangement for which our ACO seeks protection under the ACO Participation Waiver, including any material amendment or modification to a disclosed arrangement. Medicare Shared Savings Program ACO Participation Waiver Disclosure
  CMS and the U.S. Department of Health and Human Services Office of Inspector General have promulgated the MSSP “participation” waiver that, for an arrangement covered by the participation waiver, waives application of the federal Ethics in Patient Referrals Act of 1989, 42 U.S.C. § 1395nn (the “Stark Law”), and the federal anti-kickback statute, 42 U.S.C. § 1320a-7b(b) (the “Anti-Kickback Statute”). Piedmont Clinic ACO LLC (“ACO”) is currently participating in the MSSP pursuant to a Participation Agreement with CMS. The ACO seeks participation waiver protection for the arrangement(s) described below: The Piedmont Clinic, Inc. (“Piedmont Clinic”), the sole member of the ACO, operates a clinically integrated healthcare provider network on behalf of its provider members which include individual physicians, some of whom are employed by a Piedmont Healthcare affiliate and some of whom are independent. Certain but not all Piedmont Clinic members have entered into an agreement with the ACO to participate in the MSSP. From time to time, providers in the ACO refer MSSP patients attributed to the ACO to Piedmont Clinic members who do not participate in the ACO. On June 6, 2017, the ACO Board of Directors duly authorized the provision to all Piedmont Clinic members of a care coordination technology platform known as Kyruus ProviderMatch for Network Care Coordination (“ProviderMatch”), which consists of a suite of search, scheduling and referral products designed to help health networks optimize enterprise-wide patient access and care management. At the time, the ACO Board of Directors determined that the provision of Kyruus ProviderMatch to all Clinic Members (in addition to other benefits) would facilitate and optimize care coordination for MSSP patients attributed to the ACO among ACO participants and, when necessary, within the broader Piedmont Clinic network. On May 23rd, 2023, the ACO Board of Directors determined that the continued provision of the provider directory functionality of ProviderMatch continues to serve the purposes of the MSSP by facilitating specialist selection at the point of referral to optimize coordination of care for MSSP patients, and duly authorized the continued provision of the provider directory functionality to all Piedmont Clinic members. However, the ACO Board of Directors authorized a material modification of the ProviderMatch arrangement to cease the provision of the ProviderMatch search and scheduling functionalities to all Piedmont Clinic members.The ACO desires to furnish to all Piedmont Clinic members an advanced care coordination technology platform known as DexCare, which consists of a suite of provider search and scheduling products to complement the Kyruus ProviderMatch provider directory functionality and enhance enterprise-wide patient access and care management. The ACO determined that the use of DexCare by Piedmont Clinic members will facilitate quality improvement through optimization of the provider-patient match and through enhanced network clinical integration, which, in turn, will maximize the opportunities for coordination of care and application of network quality measures. On May 23rd, 2023, the ACO Board of Directors duly authorized the provision of DexCare to all Piedmont Clinic members and made a bona fide determination that each arrangement is reasonably related to the purposes of the MSSP for the reasons stated above.

• ACO Participation Waiver (Epic): On July 29th, 2021, the ACO Board of Directors duly authorized the provision of certain Epic electronic health record technology and services, Epic care coordination training, and limited hardware necessary to utilize Epic (collectively, the “Epic Arrangements”), to primary care Piedmont Clinic members who did not then utilize Epic. The ACO Board of Directors determined that the provision of the Epic Arrangements to these physicians would facilitate and optimize care coordination and population health activities for MSSP patients attributed to the ACO among ACO participants and, when necessary, within the broader Piedmont Clinic network. The ACO Board of Directors duly authorized the provision of the Epic Arrangements to primary care Piedmont Clinic members who did not then utilize Epic and made a bona fide determination that each Epic Arrangements are reasonably related to the purposes of the MSSP for the reasons stated above.”

• ACO Participation Waiver (ModusOne): On August 1st , 2023, the Piedmont Clinic ACO LLC (“Piedmont Clinic ACO”) Board of Directors duly authorized the provision of certain ModusOne Health, LLC clinical diagnosis improvement training and performance evaluation and management services (collectively, the “ModusOne Services”) to approximately 400 primary care physicians participating in the MSSP through agreements with the Piedmont Clinic ACO (“MSSP Participating Providers”). The Piedmont Clinic ACO Board of Directors determined that the provision of the ModusOne Services to these MSSP Participating Providers would: (1) benefit MSSP patients attributed to the ACO by facilitating the accurate documentation of the complete health status of MSSP patients in the outpatient medical record and providing a more complete picture of the health needs of the Piedmont Clinic ACO’s assigned population; (2) facilitate the Piedmont Clinic ACO’s meeting requirements for reporting on cost and quality measures; and (3) promote the Piedmont Clinic ACO’s accountability for the cost and quality of care of the ACO’s patient population. The Piedmont Clinic ACO Board of Directors duly authorized the provision of the ModusOne Services to these MSSP Participating Providers and made a bona fide determination that the ModusOne Services are reasonably related to the purposes of the MSSP for the reasons stated above.

• ACO Participation Waiver (Epic): On February 20th, 2025, the Piedmont Clinic ACO LLC (the “ACO”) Board of Directors duly authorized the provision of certain Epic electronic health record technology and services, including the upfront implementation costs of conversion to Epic Community Connect and payment of one year of Epic Community Connect license fees, as well as limited Epic care coordination training (collectively, the “Epic Arrangements”), to certain ACO specialists who participate in the MSSP and certain specialist providers in the broader Piedmont Clinic network who did not then utilize Epic. The ACO Board of Directors determined that the provision of the Epic Arrangements to these physicians would facilitate and optimize care coordination and population health activities for MSSP patients attributed to the ACO among ACO participants and, when necessary, within the broader Piedmont Clinic network. The ACO Board of Directors duly authorized the provision of the Epic Arrangements to these physicians and made a bona fide determination that the Epic Arrangements are reasonably related to the purposes of the MSSP for the reasons stated above.

• ACO Participation Waiver (Ellkay): The following information describes each arrangement for which our ACO seeks protection under the ACO Participation Waiver, including any material amendment or modification to a disclosed arrangement. Medicare Shared Savings Program ACO Participation Waiver Disclosure CMS and the U.S. Department of Health and Human Services Office of Inspector General have promulgated the MSSP “participation” waiver that, for an arrangement covered by the participation waiver, waives application of the federal Ethics in Patient Referrals Act of 1989, 42 U.S.C. § 1395nn (the “Stark Law”), and the federal anti-kickback statute, 42 U.S.C. § 1320a-7b(b) (the “Anti-Kickback Statute”). Piedmont Clinic ACO LLC (“ACO”) is currently participating in the MSSP pursuant to a Participation Agreement with CMS. The ACO seeks participation waiver protection for the arrangement(s) described below:The Piedmont Clinic, Inc. (“Piedmont Clinic”), the sole member of the ACO, operates a clinically integrated healthcare provider network on behalf of its provider members which include individual physicians, some of whom are employed by a Piedmont Healthcare affiliate and some of whom are independent. From time to time, providers in the ACO refer MSSP patients attributed to the ACO to Piedmont Clinic members who do not participate in the ACO. On April 2, 2025, the ACO Board of Directors duly authorized the provision to all Piedmont Clinic members of a care coordination technology platform known as Ellkay LKOrbit Pro and Ellkay LKOpera Interoperability Platform. Implementation of Ellkay LKOrbit Pro and Ellkay LKOpera Interoperability Platform to MSSP Participating Primary Care Providers, Primary Care Clinic Physicians, and other Clinic Practices who do not currently utilize Epic Technology or other platforms which are able to exchange patient information in formats that can be integrated into and shared between differing EMRs. Ellkay LKOrbit Pro and Ellkay LKOpera Interoperability Platform will provide operational capacity to exchange patient information between differing EMRs and formats of data contained in EMRs, particularly MSSP Participating Primary Care Providers, Primary Care Clinic Physicians, and other Clinic Practices who do not currently utilize Epic Technology. Further, this technology will support the interoperability of MSSP Participating Providers’ EMRs by maximizing opportunities for care coordination and population health activities. On April 2, 2025, the ACO Board of Directors duly authorized the provision of Ellkay LKOrbit Pro and Ellkay LKOpera Interoperability Platform to all Piedmont Clinic members and made a bona fide determination that each arrangement is reasonably related to the purposes of the MSSP for the reasons stated above.

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