The Physician Organization of Michigan ACO, LLC (POM ACO) is a physician-led partnership of approximately 6,000 Michigan providers working together to provide better care for patients, better health for populations and lower overall health care costs.
Physician Organization of Michigan ACO, LLC
2600 Green Road, Suite 150-C
Ann Arbor, MI 48105-4631
Terrisca Des Jardins, MHSA
Medicare Shared Savings Program ACOs
For general questions or additional information about Accountable Care Organizations, please visit www.medicare.gov/acos.html or call 1-800-MEDICARE (1-800-633-4227) TTY users should call 1-877-486-2048.
A Bahjat Shahbandar MD PC
Adrian Sheremeta MD PC
Advanced Orthopedic Specialists, PC
Agha Internal Medicine Associates, PC
Alpine Family Podiatry PC
Ankle & Foot Associates Of Northern Michigan Pc
Ann Arbor Endocrinology And Diabetes Associates, P.C..
Arthur R Jeynes DPM, PC
Associates in Physical Medicine & Rehabilitation, P.C.
Badhwar Associates Inc
Becky J Smith DO PC
Bluesky Health, PLLC
Bradley E Seel DPM PC
Brian R. Drabik DO PC
Brighton Family Physicians PC
Brooks Lyon & Brooks Do Pc
Browne Medical PLC
Cadillac After Hours Clinic PLLC
Cadillac Chiropractic Center PC
Cardiology Associates of Birmingham PC
Caritas Center for Womens Health, P.C.
Carl E Lipnik MD PC
Catherine McAuley Health Services Corp
Center for Digestive Care LLC*
Center for Plastic & Reconstructive Surgery, P.C.
Chelsea Medicine & Laser, PLLC
Chelsea Professional Services
Cherry Hill Village Family Medicine
Chowdhury MD PLLC
Clarence Richard Barnett Md Plc
Comorin Kidneycare, PLLC
Comprehensive Health Care Associates and Prevention Medicine P.C.
Corrine L Adler Do Pc
Craig J Gordon, D.O., P.C.
Creekside Vision & Hearing, Plc
Croswell Podiatry PLLC
David Fivenson MD Dermatology PLLC
DO CARE PLC
Donna J. Tal, M.D., P.C.
Downriver Internal Medicine Assoc
Dr David W Mansky DPM, PC
Dr. Jack A Dekkinga MD PC
Dr. Jeff Y The D.O.
Edith Nemeth, M.D. P.L.C.
Emmaus Health PLLC
EPMG of Michigan PC
Family Medicine PC
Forest Hills Podiatry Pc
Fowlerville Medical Center Plc
Gastroenterology Specialist PC
Gastrointestinal Specialists PC
Ghabsha, MD - PLLC
Grand Rapids Women's Health, PC
Gursharn S. Dosanjh MD PC
Harris W. Mainster, D.O./P.C.
Heart and Vascular Specialists PC
Heart Care, P.C.
Huron Gastroenterology Associates P.C.
Huron Ophthalmology, P.C.*
Huron River Radiation Oncology Specialists, P.C.
Huron Valley Radiology, P.C.
Ibtihaj Rajoulh, M.D., P.C.*
IHA Health Services Corporation
Immediate Care Medical Center PC
John D Parmely DO PC
John P Lagrand M D P C
Joseph Bruno MD PC
Josephine Iskander, MD PLLC
Kathleen Knapp Do Pc
Kiley Chiropractic Life Center
KP Karunakaran MD PC*
L Michael Sterenberg DO PLLC
Lafond Medical P C
Laura E. Babe, M.D., P.L.C.
Laura K Ganger, M.D., P.C.
Levan Internists PC
Lewis & McCorry PC
Livingston Internal Medicine PC
Loney Chiropractic, PC
Maine Medical Center Plc
Marcia Vanderbroek Do Pc
Mark S Obrien Md Plc
Mark W Sawka MD PC
Mary Lee MD PC
Mazen Sabbaq M.D. P.C.
McBain Family Chiropractic Center, PC
Medical Office Of John Vassallo Md
Michael D. ReBock DO PLC
Michigan Family Physicians PC
Michigan Orthopaedic Spine Surgeons PC
Michigan Otolaryngology Surgery
Michigan Pain Consultants, PC
Michigan Pain Institute, P.C.
Midmichigan Health Services*
MidMichigan Medical Center-Gratiot*
MidMichigan Medical Center-Midland*
Mohammed Wael Al-Meri, M.D., P.C.
Morang Chester Clinic P C
Muaiad Shihadeh MD PC
Nancy F Mansour-Habib MD PC
Naser N Sukhon MD PC
Northern Michigan Endocrine Pllc
Otsego Memorial Hospital
Packard Health, Inc.
Pamela J Hackl DO PLC
Parchment Family Practice PC
Partners In Family Health Plc
Paul DeWitt Jr. MD
Primary Care Specialists PC
Pulmonary, Critical Care & Sleep P.C.
Rama C Mulpuri MD PLLC*
Randall Street Medical PC
Rebecca Patrias, MD
REGENTS OF THE UNIVERSITY OF MICHIGAN
Renal Associates of West Michigan PC
Riverwood Family Medicine PC
Robert O. Go, M.D., P.C.
Rochester Knee and Sports Medicine PC
Ronald P. Adelman DPM, PLLC
Ronald Vanderlaan, Md, Pllc
Shehada MD PLLC
Sheldon Gonte MD
Sheldon Gonte MD
SJMHS Livingston Orthopedic Surgical Group
Soorya Sharma MD PC
Southeast Internal Medicine PLLC
St Joseph Health System Inc*
St Marys of Michigan*
St. Mary Mercy Physician Practices
Standish Community Hospital Inc*
T & J Family Medical Associates PLLC
Thornapple Ophthalmology Thornapple Ophthalmology Assoc PC
Thornapple Valley Family Physicians PC
Toni Ballitch Trate Do Pc
Vascular & Endovascular Associates PLC
West Michigan Family Health, PC
Western Michigan Bone & Joint Surgeons PC
William F Murray MD PC
ACO Participants in Joint Ventures Between ACO Professionals and Hospitals
NOTE: ACO participants involved in a joint venture are identified by an * next to their names on the Participant List.
- Steven Bernstein MD, MPH, Voting Member, ACO Participant, Regents of the University of Michigan (UM)
- Randall Bickle DO, JD, Voting Member and Compliance Officer, ACO Participant, St. Mary Mercy Physician Practices (Olympia Medical)
- Patrick Botz DO, Voting Member, ACO Participant, St. Mary's of Michigan (SMPHO)
- Brian Brausa MD, Voting Member, ACO Participant, Ankle & Foot Associates of Northern Michigan Pc (Wexford)
- Randall Clark MD, Voting Member, ACO Participant, Riverwood Family Medicine PC (Answer Health)
- Pankaj Jandwani MD, Voting Member, ACO Participant, MidMichigan Medical Center-Gratiot (MCCO)
- Madhura Mansabdar MD, Voting Member and Vice-Chair, Physician Organization Representative (MCCO)
- Robert Mee MD, Voting Member, ACO Participant, Otsego Memorial Hospital (Wexford)
- Gregory Monroe DO, Voting Member, ACO Participant, St. Mary Mercy Physician Practices (Olympia Medical)
- Kimberly Norris MD, Voting Member and Secretary, ACO Participant, Creekside Vision & Hearing PLC (Answer Health)
- Bev Nugent, MBA, Voting Member and Treasurer, Physician Organization Representative (UM)
- Timothy Peterson MD, Voting Member, ACO Executive and Chairman, ACO Participant, Regents of the University of Michigan (UM)
- Mohammad Salameh MD, Voting Member, ACO Participant, IHA Health Services Corporation (IHA)
- Jeffrey Sanfield MD, Voting Member, ACO Participant, Ann Arbor Endocrinology and Diabetes Associates, P.C. (Huron Valley Physicians Association)
- Michael Sanson MD, Voting Member, ACO Participant, Chelsea Professional Services (HVPA)
- Mark Sawka MD, Voting Member, ACO Participant, Mark W Sawka MD PC (OSP)
- Scott Silver MD, Voting Member, ACO Participant, Vascular & Endovascular Associates, PLC (United Physicians)
- Rodrigo Tobar, Jr. DO, Voting Member, ACO Participant, Family Medicine PC (Oakland Southfield Physicians)
- Marti Walsh MD, Voting Member, ACO Participant, Executive Medical Director, IHA Health Services Corporation (IHA)
- Georgiann Ziegler, Medicare Beneficiary Representative
- Terrisca Des Jardins, Non-Voting Member, POM ACO Administrative Director
- Grace Calderon, Non-Voting Member, Community Stakeholder
- Mary Greeley, Non-Voting Member, Community Stakeholder
- Maria Han, MD, Non-Voting Member, Community Stakeholder
- Jeni Hughes, Non-Voting Member, Community Stakeholder
- Melissa Kirshner, Non-Voting Member, Community Stakeholder
- Michelle Ilitch, Non-Voting Member, Community Stakeholder
- Deb Roberts, Non-Voting Member, Community Stakeholder
- Kim Speese, Non-Voting Member, Community Stakeholder
Key ACO Clinical and Administrative Leadership
- ACO Executive: Timothy A. Peterson, MD, MBA, FACEP
- Medical Director and Quality Assurance/Improvement Officer: Marti Walsh, MD
- Compliance Officer: Randall Bickle, MD, JD
- Quality Assurance and Improvement Officier: Marti Walsh, MD
ACO Committees and Committee Leadership:
- Clinical Management and Oversight: Marti Walsh, MD, Chair
- Compliance: Randall Bickle, MD, JD, Chair
- IT & Clinical Decision Support: Sandeep Vijan, MD, Chair
- Medicare Beneficiary: Georgiann Ziegler, Chair
- Operations and Finance: Jeni Hughes, Chair
Types of ACO Participants or Combinations of Participants that Formed POM ACO
- ACO professionals in a group practice arrangement,
- A network of individual practices of ACO professionals,
- A hospital employing ACO professionals,
- A federally qualified health center (FQHC), and
- A rural health center (RHC)
Second Agreement Period
Peformance Year 2016: $0
First Agreement Period
Performance Year 2015: $0
Performance Year 2014: $12,075,693
- Proportion invested in infrastructure: Approximately 50%
- Proportion invested in redesigned care processes/resources: Approximately 15%
- Proportion of distribution to ACO Participants: Approximately 35%
Performance Year 2013: $0
Payment Rule Waivers
No, our ACO does not utilize the SNF 3-day Rule Waiver.
Waivers of the Federal Fraud and Abuse Laws
ACO Participation Waiver
Physician Organization of Michigan ACO, LLC (“ POM ACO”) Operational Waivers
POM ACO has entered into a Medicare Shared Savings Program (“MSSP”) Participation Agreement with Centers for Medicare and Medicaid Services (“CMS”), effective January 1, 2013 (“Participation Agreement”). CMS and the Office of Inspector General for the United States Department of Health and Human Services (“HHS OIG”) jointly issued waivers in connection with the MSSP that waive the application of the federal fraud and abuse laws to certain MSSP arrangements, including the federal Anti-Kickback Statute and Physician Self- Referral Law so long as certain conditions prescribed by the final waivers are satisfied. One such waiver is the ACO Participation Waiver, which waives the federal fraud and abuse laws provided certain conditions are met, including the following: (i) the ACO has entered into a participation agreement and remains in good standing; (ii) the ACO satisfies certain governance, leadership and management requirements; (iii) the ACO’s governing body has made and duly authorized a bona fide determination that the arrangement is reasonably related to the purposes of the Shared Savings Program; (iv) the arrangement and its authorization are documented; and the description of the arrangement is publicly disclosed, pursuant to certain additional guidance set forth by CMS and OIG.
This document is intended to meet the public disclosure requirements set forth in the final waivers. This document will be supplemented as additional arrangements arise consistent with the timing requirements set forth by CMS and OIG in the final rule.
At a meeting on January 22, 2016, of the POM ACO Board of Managers (“Board”), the Board made a bona fide determination that certain agreements between Quality Review Organizations (“QROs”) (a list is set forth in Appendix A to this document) and QRO participants (which are defined as ACO participants) are reasonably related to the purposes of the shared savings program. In furtherance of the goals of the MSSP, POM ACO contracts with QROs to ensure quality of care provided by QRO participants in a particular region and each QRO makes payments to each of its QRO participants in a manner detailed to CMS in the Participation Agreement.
At a meeting on Janury 22, 2016, of the Board, the Board made a bona fide determination that agreements between POM ACO and each QRO are reasonably related to the purposes of the shared savings program. Each QRO provides quality improvement and similar functions at a regional level on behalf of POM ACO and furthermore, makes distributions of the shared savings payment (if earned) to its QRO participants based upon certain metrics that have been previously provided to CMS in the Participation Agreement.
At a meeting on January 22, 2016, of the Board, the Board made a bona fide determination that an agreement for independent contractor Medical Director services between POM ACO and one of its QROs was reasonably related to the purposes of the shared savings program. Consistent with existing regulatory requirements at 42 CFR Part 425, POM ACO is required to obtain the services of a Medical Director. The Medical Director provides a broad range of medico-administrative services, including, without limitation, programmatic development around various clinical initiatives, and assistance to ACO Participants with ACO readiness activities.
At a meeting on April 22, 2016, of the Board, the Board made a bona fide determination that a Management Services Agreement between POM ACO and University of Michigan is reasonably related to the purposes of the shared savings program. University of Michigan retains highly-trained staff experienced in certain areas, including, without limitation, providing clinical leadership and health informatics services. The Board has made the determination that from a cost-effectiveness standpoint, it is efficient to secure these services for POM ACO through an agreement with University of Michigan. The services provided pursuant to the agreement are explicitly defined in a budget that is pre-approved by the Board.
Pharmacy Consultation Services Waiver
At a meeting on September 22, 2017 of the Board, the Board made a bona fide determination that a Pharmacy Consultation Services arrangement between POM ACO and its Quality Review Organizations is reasonably related to the purposes of the shared savings program. Through this arrangement, POM ACO provides pharmacy consultation services to its Quality Review Organizations at no cost, and indirectly, provides this support to ACO participants in furtherance of patient care and medication management by integrating pharmacists within the health care team at the physician organization and practice level. The Board made the determination that this pharmacy support is reasonably related to the purposes of the shared savings program, including clinical integration and ensuring the availability of medication therapy management, that is beneficial to Medicare beneficiaries and is in furtherance of the quality goals of POM ACO.
Care Collaboration Arrangement Waiver (MidMichigan Medical Center - Midland)
At the June 22, 2018 meeting of the POM ACO Board of Managers, the Board made a bona fide determination that a care collaboration arrangement between the Regents of the University of Michigan (“U-M”) and MidMichigan Medical Center – Midland (“MidMichigan”) is reasonably related to the purposes of the shared savings program, including improved care coordination and quality improvement. Both MidMichigan and U-M are ACO Participants in POM ACO. Under the arrangement and at all times subject to beneficiary freedom of choice, MidMichigan inpatients will be transferred to U-M to receive certain specialized health care services unavailable at MidMichigan. Following their receipt of the specialized services, patients will be transferred back to MidMichigan by an unrelated ambulance supplier to convalesce in their local community. U-M and Midland are separated by over 100 miles and the Board has made the determination that this arrangement will improve the quality of care of patients and improve patient satisfaction by allowing patients to recover from complex procedures closer to their community. This arrangement will further the quality goals of the ACO through the coordination of care of the two ACO participants.
Care Collaboration Arrangement Waiver (St. Joseph Mercy Hospital Ann Arbor)
At a meeting on August 24, 2018 of the POM ACO Board of Managers (“Board”), the Board made a bona fide determination that a collaborative arrangement among IHA Health Services Corporation (“IHA”), St. Joseph Mercy Hospital, Ann Arbor (“St. Joseph Mercy Ann Arbor”), and Regents of the University of Michigan (“University of Michigan Health System”) is reasonably related to purposes of the Medicare Shared Savings Program, specifically, care coordination and efficient service delivery and meets the necessary requirements to grant an ACO Participation Waiver. The arrangement involves the development of a general medicine unit at St. Joseph Mercy Ann Arbor that will be staffed by University of Michigan faculty pursuant to a contractual arrangement between University of Michigan Health System and IHA. Both IHA and St. Joseph Mercy Ann Arbor are part of Trinity Health – Michigan, and both IHA and the University of Michigan Health System are currently participants in POM ACO, and anticipate transitioning to ACO tracks that are risk-bearing such that any incentive for overutilization of Medicare-payable items and services would be eliminated. The arrangement is in furtherance of ensuring care is delivered in the most efficient setting possible, in an effort to reduce costs to the Medicare program and to taxpayers, and improve patient satisfaction and quality of care. As part of this arrangement, patients will be transported by ambulance from University of Michigan Health System to St. Joseph Mercy Ann Arbor pursuant to a contractual arrangement between University of Michigan Health System and an ambulance vendor. Such ambulance transfers are medically necessary but do not meet Medicare coverage guidelines for ambulance services. Under this arrangement, Medicare beneficiaries will at all times retain freedom of choice to receive health care services from any facility.
Quality Performance Results:
2016 Quality Performance Results:
2012-2014 Quality Performance Results:
POM ACO has a number of resources for people who have a question or concern about compliance. The POM ACO Compliance Hotline has been established as a way to raise financial, regulatory and patient safety issues.
POM ACO is committed to providing an environment where individuals can safely and confidentially come forward to identify potential serious inquiries.
Callers to the POM ACO Compliance Hotline can remain anonymous. Customary resolutions methods, such as talking with your supervisor or physician organization's leaders, are still important first-line approaches for reporting compliance concerns to try to reach a resolution locally.
The POM ACO Compliance Hotline is available for situations where conventional channels are uncomfortable or otherwise inappropriate, or when you wish to remain anonymous. Please keep in mind however, that certain types of reports may be difficult to pursue if you choose to remain anonymous.
POM ACO has contracted with a professional compliance call center to handle the calls and route information back to the appropriate areas for handling. You may contact them by phone or by submitting an on-line form 24 hours a day, 7 days a week.
Toll free number 1-855-260-0919
On-line form www.reportlineweb.com/pomaco