Paul Clark, a legal analyst at Wolters Kluwer, says the incentives for annual improvement indicate CMS are both determined and flexible in the agency's efforts to optimize MSSP.
"CMS is proposing to reward not just ACOs that meet the existing quality measures, but that show year-to-year improvements in specific areas. This 'explicit incentive,' in CMS's words, is to emphasize that meeting quality goals is not a static, one-time result, but an evolving process," he says. "This is one of the reasons CMS is changing the MSSP quality measures on a regular basis."
The deadline for healthcare industry stakeholders to comment on the proposed changes to 2015 Medicare B payment rules, including ACO regulations, is Sept. 2. CMS officials have solicited comments on several possible new MSSP quality standards such as care coordination, prevention and utilization.
Mikuckis says federal officials appear to be gearing the MSSP model of accountable care for the long haul.
"Taken as a whole, the rule changes and the request for comments seem to point to the fact that MSSP is on a path toward trying to drive further improvement and impact in ACO performance, and increasingly transitioning to a broad range of quality outcomes metrics that reflect the main priorities that ACOs should focus on in improving population health," he said.