A Centers for Medicare & Medicaid Services executive says the agency is considering developing an accountable care organization-type model for beneficiaries who qualify for both Medicare and Medicaid.

Creating this type of model would be complex, acknowledged Patrick Conway, M.D., CMS Deputy Administrator for Innovation & Quality and Chief Medical Officer, speaking at the National ACO Summit. He said CMS has begun discussions with some states and providers about the concept.

In addition to needing willing states and providers, an ACO for dual eligibles would have to take into account the variety of beneficiaries eligible for both Medicare and Medicaid said Keith Fontenot, managing director of government relations and public relations at Hooper, Lundy & Bookman in Washington D.C., in an email to the Bloomberg Bureau of National Affairs.

Fontenot wrote that providers used to dealing primarily with healthy, older Medicare beneficiaries may be inexperienced in providing care for beneficiaries with behavioral or mental health challenges, since dual eligibles “include a significant number of younger and disabled patients.”

Health policy experts say if CMS were to implement an ACO-style care model, it shouldn’t be mandatory for states.

CMS should avoid imposing a “one-size-fits-all” dual eligible model, said Health Policy Source’s Jenny Gladieux, speaking to the Bloomberg.

“If they develop such a model, I hope it is voluntary for states to adopt,” Gladieux said. Gladieux added that at least 15 states have taken an ACO approach with their Medicaid populations.