Eleven provider organizations support the proposed ACO changes
Groups hail policies to increase COA participation
September 1, 2022 — In comments submitted today to the Centers for Medicare and Medicaid Services (CMS) in response to the proposed 2023 Medicare Physician Fee Schedule, 11 leading national healthcare associations and stakeholder groups applauded the work of the agency to increase participation in Responsible Care Organizations (ACOs) in Medicare. The settlement, if finalized, would make several positive changes to the Medicare Shared Savings Program (MSSP), Medicare’s largest value-based payment model, including giving ACOs more time before moving to highest levels of risk, by providing fairer and more precise financial benchmarks. , making positive changes to quality scoring approaches, and providing shared savings advance payments to small ACOs that serve underserved populations.
“We appreciate that many of the changes proposed in this rule respond to recommendations we have made to improve the MSSP,” the letter states. “Ultimately, many of these proposals will help increase participation in ACOs and achieve CMS’s stated goal of having all Medicare beneficiaries in a relationship with one provider who is accountable for quality and cost. total care.”
Specifically, the letter asks CMS to:
Expand the types of ACOs that can receive advanced investment payments offered in the MSSP. Advance payments should be available to all CCOs striving to achieve health equity.
Refocus the distinction between high and low income ACOs to respond to the characteristics of the beneficiaries served by an ACO. Although the groups appreciate the proposed changes to the progression of COAs through risk, COAs that include certain providers like safety net hospitals and rural health clinics will generally not benefit from the proposed changes, which undermines the work of the agency to address health disparities.
Allow existing ACOs to accept proposed benchmarking and risk adjustment policies. The vast majority of existing ACOs will not have access to these enhanced policies for several years, excluding them from their benefits.
Engage stakeholders in designing benchmarks for the future. The groups applaud CMS for recognizing the need for a long-term solution to the “ratchet effect” of benchmarking with administrative benchmarks, but the agency needs robust dialogue with stakeholders to avoid any unintended consequences.
Reconsider timing and other ACO requirements for requiring electronic quality reports. While many of the proposed changes are a step in the right direction, more work needs to be done to ensure a smooth transition to electronic reporting of clinical quality measures.
Supports an extension of advanced APM bonuses. While it is ultimately up to Congress to extend the large 5% incentive payouts, CMS management could work with Capitol Hill to ensure adequate incentives for APMs.
Use MSSP as an innovation platform. CMS could leverage ACOs to test new concepts typically reserved for CMS Innovation Center models, such as a full-risk track, primary care capitation, and other public health emergency waivers.
The letter was signed by America’s Essential Hospitals, American Academy of Family Physicians, American Medical Association, AMGA, Association of American Medical Colleges, Federation of American Hospitals, Health Care Transformation Task Force, Medical Group Management Association, National Association of ACOs, National Rural Association for Health and Premier, Inc.
Since 2012, ACOs have saved Medicare $13.3 billion in gross savings and $4.7 billion in net savings. Importantly, the data shows that these ACOs have continued to provide high quality care and produce satisfied patients. The data also shows that these ACOs have continued to provide high quality care and produce satisfied patients. Today, ACOs support nearly 20 percent of all Medicare patients and nearly one-third of traditional Medicare patients. Importantly in Medicare, ACOs allow patients to retain their choice of provider, and there are no network restrictions or prior authorization use.
About NAACOS. The National Association of ACOs (NAACOS) represents more than 13 million beneficiary lives through hundreds of organizations participating in population health-focused payment and delivery models in Medicare, Medicaid and commercial insurance . Models include the Medicare Shared Savings Program (MSSP), global and professional direct contracts, and alternative payment models supported by a myriad of commercial health plans and Medicare Advantage. NAACOS is a member-directed and owned not-for-profit organization that strives to improve the quality of care, outcomes and cost-effectiveness of healthcare.