Developing Effective ACH Governance
Technical Assistance Resource
May 2017
Overview
2
 ACH governance & organizational structure requirements
 Effective ACH governance
 Governance chart
 Decision-making processes
•
Transparency
•
Voting thresholds
•
Workflows
•
Dispute resolution
 Formalized structures: Conflicts of interest
 ACH governance evolution
ACH Governance & Organizational Structure Requirements
Governing Body Composition &
Participation*
 The ACH decision-making body must include
voting partners from seven categories,
including: primary care, behavioral health,
health plans (MCOs), hospital or health
system, local public health jurisdiction, tribe /
IHS facilities, and community based partners
 The ACH is expected to establish a governing
body in which:
 No one group can dominate the decisionmaking process
 All counties are represented (or
demonstrate a concerted effort was made
to include them)
 At least 50% of the primary decision
making body must be non-clinical, nonpayer participants
 The ACH must also establish and implement a
consumer engagement plan to ensure local
needs, priorities and inequities are taken into
consideration during decision making
3
Governing Body Management**
 Each ACH must identify a primary decision-making
process, a process for conflict resolution and structure
(e.g., a Board or Steering Committee) that meets
composition and participation requirements.
 The ACH must establish an organizational structure
coupled with its processes that demonstrate the
capability to make decisions and be accountable for the
following domains:
 Financial – allocation methodology, roles and
responsibilities, budget development
 Clinical – expertise and management for monitoring
clinical outcomes
 Community – health equity, process to engage
community and consumers
 Data – processes and resources to support datadriven decision making and formative evaluation
 Program Management and Strategy Development –
organizational capacity and administrative support
for regional coordination and communication for the
ACH
NOTE: Any reference to Boards / Directors are directional and not intended to suggest that alternative structures are not feasible options.
* See STC 23 for a full list of categories that must be represented
** See STC 22 for a full description of the ACH management requirements
Effective ACH Governance
4
Effective governance is the framework of established rules and practices that ensure accountability, fairness,
transparency and efficiency in an organization’s relationship with its stakeholders and community partners.
Critical Elements of Good Governance
•
Lessons Learned
Experience from other multistakeholder engagements –
including New York and New
Hampshire DSRIP – highlight
two critical elements of good
governance.
Clear Decision-Making Processes: Define and
implement processes for transparent decision-making,
dispute resolution and communicating decisions
•
•
Today’s focus: Decision workflows, voting
thresholds & dispute resolution
Formalized Structures: Form committees, work groups,
and councils, guided by charters to define roles and
clear mechanisms for moving recommendations
forward and ensuring accountability
•
Today’s focus: Conflicts of interest
Establishing effective financial control and ensuring a commitment to the vision and mission are critical elements of
good governance that will be addressed in other Manatt technical assistance materials.
Governance Chart – Example
5
A sample ACH governance structure is detailed below, highlighting a governing body and a set of committees
organized around the decision-making domains outlined in the STCs.
• Each committee has oversight of a specific
area (e.g., finance, clinical) and evaluates and
makes recommendations to the executive
committee and/or the governing body
• The work groups illustrated are responsible
for developing and implementing plans (e.g.,
assessing options for an analytics capability,
recommending a care coordination project)
Finance
Committee
Governing Body
(e.g., Board, Steering
Committee)
Executive
Committee
Clinical Affairs
Committee
Data Committee
Care Coordination
Work Group
Analytics Work
Group
Regional Health
Improvement
Council
Community
Engagement
Committee
NOTE: This structure is intended to be illustrative and not intended to suggest that alternative structures are not feasible options.
The regional council has
a broader
representation than the
governing body. It
reviews health
assessments and
advises the governing
body on regional health
priorities and how to
address them.
Program
Management
Committee
Decision-Making Processes
6
Formalized decision-making processes are critical for a fair, transparent, efficient governing body charged with
making a broad range of critical decisions.
•
Goals of Establishing Effective Decision-Making
Processes are to:
Make timely decisions that enable the ACH to fulfill
its responsibilities
•
Establish clear methods for community and
stakeholder input prior to decision
•
Appropriately escalate recommendations /
decisions across levels of the governance structure
•
Ensure transparency of decisions and how they are
made
•
Provide mechanism to resolve disputes
•
Communicate decisions across all levels of the ACH
structure and among participants, stakeholders and
community partners
Critical Decisions for ACHs
• Member selection for governing
body and committees
• Project selection, planning and
implementation
• Partner selection
• Stakeholder engagement
• Performance monitoring &
reporting
• Financial planning & oversight
• Fund allocation process definition
& application
• Dispute resolution
Decision-Making: Transparency
7
Transparent decision-making is critical in the context of ACHs’ intended role in Medicaid transformation –
both for gathering community input and as a mechanism for disseminating information.
Gathering Community
Input and Perspective
Incorporating methods for soliciting stakeholder
input into formalized decision-making processes
enables a governing board to:
 Gather input and perspective on community
needs
 Review existing efforts and test planned efforts
Methods for soliciting stakeholder input could
include community meetings, focus groups, public
comment periods, calls for project suggestions,
among other activities.
Sharing Information
& Ensuring Transparency
Sharing information with stakeholders and tribes, as
well as partners and the public at large, ensures
transparency into ACH governance and project
selection and promotes stakeholder engagement.
HCA requires that all governing body meetings at
which DSRIP-related decisions are made be public.
Additional information sharing could include making
meeting agendas and minutes, as well as other
pertinent project materials, available to all of the
partners on a website, or via email dissemination for
partners who elect to receive them.
ACH technical assistance focused on stakeholder engagement will be forthcoming, which will delve into
strategies and best practices for engaging a variety of stakeholders.
Decision-Making: Voting Thresholds
8
There are a range of voting thresholds that can be incorporated into the decision-making process of each group.
Voting options can vary across bodies in the governance structure (e.g., work group & committee).
Simple Majority
Super Majority
Unanimous
Agreement
• At least 50% of the votes required to
reach a decision
• 2/3 or 75% of the votes required to reach a
decision
• 100% agreement is required to
reach a decision
• Relatively quicker decision making
process than others that require higher
thresholds of agreement
• Requires input and agreement from more
group members, including those with minority
opinions
• Those with minority opinions may feel
excluded from the decision-making
process
• Facilitates more group members feeling
invested in the chosen outcome
• Requires participation and an
environment that fosters
mutual respect and healthy
communication
• Susceptible to abuse if the group itself
is unbalanced
• Generally used for relatively routine
decisions (e.g., approving annual
budget)
• Requires an environment that is conducive to
healthy discourse
• Requires more time than a simple majority
• Generally used for decisions that have a
foundational impact (e.g., project selection)
• Minority opinions may have to
concede
• Time consuming and decisionmaking can be inefficient
• Generally reserved for decisions
that change the direction of an
organization
Regardless of the threshold selected, the overall goal should be to achieve
consensus as much as possible to ensure all parties feel heard and invested
Decision-Making: Example Process – Fund Allocation
9
An example of utilizing a decision-making methodology for fund allocation is highlighted below.
ILLUSTRATIVE
SITUATION:
Committee is charged
with determining how
incentive funds will be
distributed among
community partners.
Identify the
Decision
Clearly define
the purpose of
the decision
• How should
incentive
funds be
distributed
to our
community
partners?
Gather
Information
Collect pertinent
information
• Performance
data based on
targets
• Projected
impact with
additional
funding
• Approaches
used by other
similar entities
• Perspectives
from partners &
stakeholders
Principles for
Evaluating
Alternatives
Establish
baseline criteria
• Aligned with
mission and
vision?
• Number of
community
members
impacted?
• Measurable
impact?
Identify
Alternatives
Weigh the
Evidence
Evaluate each
alternative
Brainstorm to
list all ideas
• Distribute
based on
achieving
performance
targets
• Distribute
based on
number of
people
served
• Distribute
funds evenly
across all
partners
• Review pros
and cons of
each
alternative
• Develop
financial
scenarios
based on
each
alternative
Choose Among
Alternatives
Select the
alternative
• Come to
agreement
on how to
distribute
incentive
funds among
community
partners
Take
Action
Convert
decision into a
plan
• Document
funding
allocation rec
and process
for
distribution
• Escalate to
governing
body for
finalization
Review
Decision
Consider
results and
evaluate
whether or
not it has
resolved the
need
identified
• Governing
body
reviews
recommend
ation and
votes to
finalize
Communicate
Decision
Communicate
decisions with
stakeholders
and
community
• Communicat
e incentive
fund
allocation
decision to
community
partners and
stakeholders
Decision-Making: Example Workflow – Analytics Capability
10
Each ACH will need to define a decision-making workflow to advance decisions through its governance structure,
as demonstrated in the example below.
ILLUSTRATIVE
SITUATION:
Recognizing its need to
develop analytics
capability, an ACH
charges a work group
with assessing options
and making a
recommendation to
the larger governing
body.
1
Analytics
Work Group
Gather input to define
required analytic
capabilities and identify
options (e.g. hire,
outsource, in kind)
Narrow options
against defined
needs and work
group (WG) votes on
recommendation
Vote to
advance
recommendations?
YES
NO
Stakeholders
Tribes
NO
4
Communicate
decision to ACH
organization &
community
stakeholders
2
YES
Vote to
adopt
recommendations?
3
Work group revisits
decision and/or
creates issues list to
elevate
ACH Governing
Body
Evaluate and
vote on WG
recommendation
YES
NO
Executive
Committee
Is estimated
investment
> $X?
Decision-Making: Example Workflow – Project Selection
11
Each ACH will need to define a decision-making workflow to advance decisions through its governance structure,
as demonstrated in the example below.
ILLUSTRATIVE
SITUATION:
The Care Coordination
Work Group is charged
by the Clinical Affairs
committee with
reviewing and
evaluating potential
projects to make a
recommendation on
which projects to
move forward with.
5
Communicate
decision to ACH
organization &
community
stakeholders
Governing
Body
Evaluate
recommendation
NO
YES
Vote to
adopt
recommendation?
4
NO
Review existing and
planned community
efforts focused on
care coordination
Stakeholders
Tribes
Narrow against principles 3
2
Review list of
potential
projects
Community
Partners
Define investment
required and
projected return
Work group revisits
recommendation
and/or creates
issues list to elevate
1
Gather community
input
Validate
and
approve?
Finance
Committee
Review
community needs
Care
Coordination
Work Group
YES
– alignment with vision,
community needs and
potential impact,
investment required,
stakeholder engagement,
measurability
Clinical Affairs
Committee
NO
Vote to
advance
recommend
ation?
YES
Decision-Making: Dispute Resolution
12
Establishing a dispute resolution mechanism at all levels of interaction enables an ACH to quickly address
issues if they do arise.
Dispute Resolution Mechanism
for Issues that Arise:
Example Dispute Resolution Processes
Between HCA and the ACH
To be governed by the dispute resolution process set forth in the HCA/ACH
agreement:
The initiating party will reduce its description of the dispute to writing and
deliver it to the responding party (email acceptable). The responding party
will respond in writing within five (5) Business Days (email acceptable). If
after five (5) additional Business Days the parties have not resolved the
Dispute, it will be submitted to the HCA Director, who may employ whatever
dispute resolution methods the Director deems appropriate to resolve the
Dispute.
Between ACH and a provider partner
Could be subject to a similar process as described above but with an
outside arbitrator or mediator agreed on by the parties brought in if the
parties cannot resolve the dispute.
Within a work group or committee, or
between work groups or committees
Could be subject to a similar process as the above two examples, but with
the governing body making the final decision.
Formalized Structures: Conflict of Interest
13
The governance body should have a conflict of interest (CoI) policy in place that requires at a minimum that those
with a conflict or potential conflict are: (1) Required to disclose it, and (2) Prohibited from voting on any matter
with respect to which they have a conflict, and must recuse themselves during any such vote.
Key Components of CoI Policy:
 Purpose
Healthier Washington
Example Conflicts of Interest Policy for ACHs
May 2017
[INSERT NAME OF ORGANIZATION]
Conflicts of Interest Policy
 Definitions
 Procedures
Article I
Purpose
The purpose of this Conflicts of Interest Policy is to protect the interests of [INSERT NAME OF
ORGANIZATION] when [INSERT NAME OF ORGANIZATION] is contemplating entering
into a transaction or arrangement that might benefit the private interest of any member of the
Board of Directors or any Committee or Subcommittee of [INSERT NAME OF
ORGANIZATION].
Article II
Definitions
1.
•
Duty to Disclose
Interested Person
Any member of the Board of Directors of [INSERT NAME OF ORGANIZATION] or any
Committee or Subcommittee of [INSERT NAME OF ORGANIZATION] who has a direct or
indirect financial interest, as defined below, is an interested person.
2. Financial Interest
A person has a financial interest if the person has, directly or indirectly, through business,
investment, or a relative (as defined herein):
•
Determining Whether a Conflict of Interest Exists
•
Procedures for Addressing the Conflict of Interest
•
Violations of the Conflicts of Interest Policy
 Records of Proceedings
 Annual Statements
a. An ownership or investment interest (35% or greater ownership or beneficial interest,
or if the entity is a partnership, a direct or indirect ownership exceeding 5%) in any
entity with which [INSERT NAME OF ORGANIZATION] has or with which
[INSERT NAME OF ORGANIZATION] is considering entering into a transaction or
arrangement;
b. A compensation arrangement with [INSERT NAME OF ORGANIZATION] or with
any entity or individual with which [INSERT NAME OF ORGANIZATION] has or
with which [INSERT NAME OF ORGANIZATION] is considering entering into a
transaction or arrangement; or
c. A potential ownership or investment interest in, or compensation arrangement with,
any entity or individual with which [INSERT NAME OF ORGANIZATION] is
negotiating a transaction or arrangement. Compensation includes direct and indirect
remuneration as well as gifts or favors that are not insubstantial. A financial interest
is not necessarily a conflict of interest. Under Article III, Section 2, a person who has
An Example Policy is
Available at:
www.ACHTA.org
Conflict of Interest: Example Cases
14
1. If the board or a committee is deciding how much money to provide to a specific
participant, and there is a representative of that participant on the board or the
committee, that representative would have a conflict and would have to recuse
him/herself from the decision.
2. If a significant number of board or committee members represent providers and
MCOs, and there is a decision to be made that will impact both the provider and
the MCO community generally, it may not be feasible for all of those board or
committee members to recuse themselves from the decision, but they must be
mindful of the fact that when acting as board or committee members, their
fiduciary duty is to the ACH, and not to their organizations.
Conflict of Interest: Tips for Identifying & Addressing CoI
15
Governance Body Conflict of Interest (CoI) Policy
As the ACH moves to planning and operational governance structures, the following practices can
ensure that a CoI can be identified and addressed on an ongoing basis as decision-making needs
evolve:
 Recognize that in a community-based organization, conflicts can be more subtle than in other
organizations (e.g., dual-loyalties related to other boards, foundations, organizations donated to)
 Take time regularly (e.g., annually, semi-annually) to discuss potential conflicts of interest, and how
the governing body would address the situation
 Reflect any conflicts of interest and how they were addressed in the meeting minutes to ensure
transparency
 Circulate a questionnaire or disclosure to see if members’
situations have changed and if new conflicts of interest have
arisen
An Example Policy is
Available at:
www.ACHTA.org
Source: https://www.councilofnonprofits.org/tools-resources/conflict-of-interest
ACH Governance Evolution
16
As ACHs transition from planning governance to operational governance, the governing body must shift in its
focus and perspective and build different capabilities over time.
The structure and goals of governance will evolve.
Convening
Committee
Historic Role of ACH
• Bring together
stakeholders,
tribes and
community
members
Planning Governance
DY* 1
DY 2 – 5
Where are you today and what do you
need to be an effective ACH?
How to transition to an
implementation focus?
• Align existing governing bodies with
the requirements in the Demonstration
• Provide oversight of Project
Plan milestones, and enforce
participant obligations
• Ensure ACH meets certification
standards and develops and submits
Project Plan Application
• Establish an effective and collaborative
system that engages stakeholders,
tribes and the community
• Oversee ACH finances to ensure they
are disbursed in support of the mission
• Requires rapid decision-making and
ongoing communications
* Demonstration Year
Operational Governance
• Ongoing planning for
sustainability
• Evaluate/track performance
relative to established metrics
• Requires maintaining ongoing
commitment of stakeholders
and partners as well as
ongoing communications
PostDemonstration
Governance
How do you continue to
meet the needs of the
ACH and the
community?
• Ensure governing body
remains relevant to
the changing needs of
the community after
incentive period ends
• Ensure long-term
sustainability by
establishing new
funding sources for
ACH functions
17
Need help with a specific area of
your governance model?
Contact your Regional Coordinator
who can connect you with the
most appropriate resource.
Appendix
18
 Purpose of a governing body
 Principles of good governance
 Formalized structures: Charter
 Decision-making processes: Critical steps
 STC 22 & 23
Purpose of a Governing Body
19
The purpose of a governing body is to ensure the organization is on track with regard to meeting its
goals, as well as to craft policies in support of those goals.
There are two distinct groups in an organization: the governing body, which determines policies and
plans and oversees work, and the organization staff, which carries out plans and implements policies
Governing Body Responsibilities
•
Hiring the top executive and holding him
or her accountable for oversight of
program implementation
•
Strategic Planning – providing guidance for
overall direction and project selection
•
Policy Development for program
implementation
•
Stakeholder and Tribal Engagement –
ensuring adequate representation
•
Fiduciary Responsibility – approving
budget and ensuring that funds are used in
support of the overarching mission
Principles of Good Governance
20
Good governance promotes effective decision making to execute against the ACH’s vision while fostering
community trust and engagement.
Good Governance Is:
Accountable: The ACH governing body has an obligation to report, explain and be answerable for the decisions it
makes on behalf of the communities it represents.
Transparent: Stakeholders must be able to follow and understand the decision-making process. They should be able to
clearly see how and why a decision was made – what information, criteria and advice was considered.
Fiscally Responsible: The ACH governing body is responsible for oversight of the organization’s finances and ensuring
funds are budgeted and disbursed in support of the mission
Responsive: The ACH should always try to anticipate and respond to the needs of its community while
balancing competing interests in a timely and appropriate manner.
Balanced and Representative: A community’s wellbeing results from all of its members, particularly the most
vulnerable, feeling their interests have been considered in the decision-making process.
Participatory and Inclusive: All stakeholders affected by or interested in a decision should have the opportunity to
provide input to or, in some cases, be part of the decision-making process.
Following the Rule of Law: The ACH is obligated to have a fair legal framework that is enforced impartially.
Effective and Efficient: The ACH should implement decisions and follow processes that make the best use of available
people, resources and time to ensure the best possible results for their community.
Formalized Structures: Definitions
21
The STC’s guidance on ACH governance structures allows for variability to best meet the needs of the community.
As such, some common definitions of organizational structure elements are described below.
Governing Body: A group of people whose role is to represent, plan strategic direction,
set the organization’s goals, lead the organization, make the policies, oversee financial
direction and accountability, and supervise and evaluate management. Inclusive of
Boards and Steering Committees.
Council: A council is a group of people or experts in their respective fields who come
together to make decisions and deliberate. This is often a large body whose members
serve as representatives of stakeholders and the broader membership.
Committee: A committee is usually a small group, often formed to discuss specific
matters at hand. Committees represent and report to larger bodies. Committees can
be formed to conduct research or come up with recommendations for planned
projects or changes.
Work Group / Sub-Committee / Task Force: A group convened to develop an execute
an implementation plan.
Formalized Structures: Charter – Example
22
Charters are essential for the governing body and all committees, workgroups and councils. The high level
categories of an effective charter are described below, using the clinical affairs committee as an example.
Clinical Affairs Committee Charter
ILLUSTRATIVE
Standard Across
Committees
Committee
Specific
Charge: Responsible for overseeing the development of project plans for each clinical program; oversight of 3 project
work groups including, primary care transformation, care coordination, and transitional care.
Responsibilities: Responsible for the development, oversight and implementation of project plans; oversight of the
three clinical project work groups and their plan development; and coordination among the work groups and with the
executive committee and governing body.
Composition: Representative membership, including both clinical and non-clinical members; critical to implementing
the vision of the ACH. This will include a process for selecting/ appointing members and co-chairs; description of roles
and responsibilities of the co-chairs; and an established process for modifying committee representation.
Meetings: Meeting frequency and duration, minimum number of members required, specific duties and time
commitment, and member expectations around meeting attendance and preparation
Decision Making and Dispute Resolution: Description of decision-making, escalation and dispute-resolution processes
Reporting and Recording: Expectations for maintaining and circulating meeting minutes, and posting publicly for
participants
Conflicts of Interest: Reminder that all members are required to comply with conflicts of interest policy
NOTE: The charge, responsibilities and composition portions of a charter are committee specific , while the remaining sections are more
standard across committees.
Tip: Governance vs. Management – Example
23
As the ACH builds capacity, the distinction between governance – direction setting and decision making – and
management – executing on projects and activities and making recommendations to the governing body – is important.
ILLUSTRATIVE
Governance represents the vision of the
organization and addresses the question “What
are we going to do to fulfill the Mission and
Vision?”
Finance Committee
•
•
•
•
Management exists to carry out the functions of
the organization and addresses the question “How
are we going to accomplish the goals and
objectives?”
Finance Director and Team
•
The finance committee has oversight of the
ACH’s budget as well as responsibility for
evaluating project requests and making
recommendations to the governing body
Establish $ thresholds of projects that can
move forward without review by the
committee
Establish principles and decision making
criteria against which they evaluate projects
and financial requests
Review and approve funds flow and budget
•
•
•
•
•
Carry out day to day financial operations of the
ACH
Coordinate across committees and work groups to
manage adherence to budget and identify items
that need to go to the finance committee
Implement agreed upon projects
Gather necessary information and present to
finance committee along with recommended
actions
Establish budget for finance committee approval
Evaluate performance of specific work group
activities against targets / goals
Decision-Making Processes: Critical Steps
24
While the decision making processes of a governing body will be tailored to the organization, some best practice
steps are highlighted below.
Decision making is the process of making
choices by identifying a decision,
gathering information and assessing
alternative resolutions.
Identify the
Decision
Clearly define
the purpose of
the decision
• What exactly
is the
problem?
• Who are the
affected
parties?
• Is there a
deadline or
specific
time-line?
Gather
Information
Collect
pertinent
information
• Internal and
external
sources
• Related to
the factors
and
stakeholders
involved
Principles for
Evaluating
Alternatives
Establish
baseline criteria
• Budgetary
impact and
alignment
with vision
and mission
should be
included
Identify
Alternatives
Brainstorm to
list all ideas
• Utilize
cause and
effect
diagrams
and pareto
charts to
identify and
prioritize
causes
• Include “do
nothing” as
an option
Weigh the
Evidence
Use your
judgment
principles and
decisionmaking criteria
to evaluate
each
alternative
Choose Among
Alternatives
Select the
alternative
• Based on an
informed
process that
follows a
methodology
Take
Action
Convert
decision
into a plan
or
sequence
of
activities
Review
Decision
Consider
results and
evaluate
whether or
not it has
resolved the
need
identified
Communicate
Decision
Communicate
decisions with
stakeholders
and
community
• Weigh the
positives and
negatives of
each option
This basic process can
be used in governing
bodies, committees,
work groups, etc.
Tip: How to Run an Effective Meeting
25
Best practice organizations establish and adhere to a meeting structure – for work groups, committees, and the
governing body - that allows them to efficiently move through the issues and effectively make timely decisions.
Prepare for the meeting and distribute materials ahead of time, including past meeting minutes.
Minimize meeting time spent on items on which everyone is in agreement by combining the reports
requiring no action and the minutes into a consent agenda at the beginning so that discussion only
occurs on these items if there is an objection
Prioritize remaining reports so that their most significant decisions can come about with the freshest
minds
Stick to a Schedule and set time-limits on reporting, discussion and debate so that if the body is not
ready to make a decision on one item, others may still receive a fair hearing
Set Clear Boundaries on the role of the governing body and that of staff and management
Make Decisions Once by making them clear and broad rather than technical and limited
Maintain Strategic Perspective by adjourning with a sense of what is next for the following meeting
ACH Governance Structure Requirements: STC 22
STC 22 - ACH Management
Each ACH must identify a primary decision-making process, a process for conflict resolution and structure (e.g., a
Board or Steering Committee) that is subject to the outlined composition and participation guidelines. The
primary decision-making body will be the final decision-maker for the ACH regarding the selection of projects
and participants based on the regional needs assessment. Each ACH and the state will collaborate and agree on
each ACH’s approach to its decision-making structure for purposes of this demonstration. The overall
organizational structure established by the ACH must reflect capability to make decisions and be accountable for
the following five domains, at a minimum. The ACH must demonstrate compliance with this STC in the ACH
Project Plan.
a. Financial, including decisions about the allocation methodology, the roles and responsibilities of
each partner organization, and budget development.
b. Clinical, including appropriate expertise and strategies for monitoring clinical outcomes. The ACH will
be responsible for monitoring activities of providers participating in care delivery redesign projects
and should incorporate clinical leadership, which reflects both large and small providers and urban
and rural providers.
c. Community, including an emphasis on health equity and a process to engage the community and
consumers.
d. Data, including the processes and resources to support data-driven decision making and formative
evaluation.
e. Program management and strategy development. The ACH must have organizational capacity and
administrative support for regional coordination and communication on behalf of the ACH.
26
ACH Governance Structure Requirements: STC 23
27
STC 23 – ACH Composition and
Participation
At a minimum, each ACH decision-making body must include voting partners from the following categories:
a. One or more primary care providers, including practices and facilities serving Medicaid beneficiaries;
b. One or more behavioral health providers, including practices and facilities serving Medicaid beneficiaries;
c. One or more health plans, including but not limited to Medicaid Managed Care Organizations; if only one opening is available
for a health plan, it must be filled by a Medicaid Managed Care Organizations;
d. One or more hospitals or health systems;
e. One or more local public health jurisdiction;
f. One or more representatives from the tribes, IHS facilities, and UIHPs in the region, as further specified in STC 24;
g. Multiple community partners and community-based organizations that provide social and support services reflective of the
social determinants of health for a variety of populations in the region. This includes, but is not limited to, transportation,
housing, employment services, education, criminal justice, financial assistance, consumers, consumer advocacy
organizations, childcare, veteran services, community supports, legal assistance, etc.
The ACHs must create and execute a consumer engagement plan as part of the ACH Project Plan. The consumer engagement plan will
detail the multiple levels of the decision-making process to ensure ACHs are accurately assessing local health needs, priorities and
inequities. As part of the ACH Project Plan ACHs must provide documentation of at least two public meetings detailing how their
proposal incorporates feedback from the public comment process.
To ensure broad participation in the ACH and prevent one group of ACH partners from dominating decision-making, at least 50 percent
of the primary decision-making body must be non-clinical, non-payer participants. In addition to balanced sectoral representation,
where multiple counties exist within an ACH, a concerted effort to include a person from each county on the primary decision-making
body must be demonstrated.