Medical device companies are warning Medicare to make sure its forthcoming accountable care organization model ensures doctors aren't rewarded for using lower cost devices or stinting on patient care.

In letters sent this week to the Centers for Medicare and Medicaid Services and the Inspector General's office of the Department of Health and Human Services, the medical device lobby AdvaMed called for stronger oversight of ACO programs and guidelines so early adopters of technology don't get penalized.

"ACOs are designed to generate savings by better coordinating group care," David Nexon, senior executive vice president with AdvaMed, said in a call with reporters Wednesday, "not by doctors giving less [care] to patients."

The letters from the lobby, also known as the Advanced Medical Technology Association, were sent during the public comment period on the proposed rules for the Medicare Shared Savings Program, a plan stipulated by the Affordable Care Act. The comment period ended Monday.

[Read why ACOs might not achieve promised cost-savings.]

In principle, ACOs are networks of providers, clinics, long-term care facilities and hospitals that work together to reduce costs and raise quality. The group is then eligible to pocket some of the savings it gets by cutting back on duplicate procedures or keeping chronically ill patients healthy and out of the emergency department.

In proposed rules released in March, CMS said it would link the shared savings with doctors meeting 65 quality metrics. The ACOs would also have to serve a minimum of 5,000 patients -- considered a tall order by some medical societies.

To participate in the program, which starts next year, providers will likely need waivers for some aspects of civil monetary penalty, anti-kickback and self-referral statutes. But medical device companies fret that if these waivers aren't narrowly tailored they could risk giving financial incentives to doctors to opt for cheaper medical treatments. These treatments could be clinically less effective -- and, of course, forswearing newer, more expensive technologies would hurt device companies.

Recommendations to CMS from the device manufacturers include:

• An independent clinical care monitoring program that would review patient records, and not just claims, and compare utilization of services between ACO beneficiaries and non-ACO beneficiaries, to ensure ACO beneficiaries weren't getting less appropriate services.

• Actions to ensure patients have given their full consent, and work so that gainsharing distributions are based on team efforts and not just cost-savings by individual physicians.

• Protections for early adopters of new technology when ACOs set up their 3-year plans.

One example the group gave for reviewing ACO programs was checking for inappropriate substitutions from Medicare Part D drug plans. Because benchmarking for Part A and B treatment costs exclude Part D services, providers could opt for a possibly less effective drug from Part D as it wouldn't count against their ACO financial targets, AdvaMed said.

"But it may not be a real saving at all," Nexon said. "You shouldn't have an artificial incentive to do it."