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Why These 9 Groups Want CMS to Limit Medicare ACO Changes

Analysis  |  By Steven Porter  
   September 21, 2018

The organizations pushed for two edits, in particular, in a letter to CMS Administrator Seema Verma.

Nine organizations, including the National Association of Accountable Care Organizations (NAACOS), sent a letter Thursday urging the Centers for Medicare & Medicaid Services to back off some, but not all, of the changes proposed for 2019 to the Medicare Shared Savings Program.

The letter pushed for two edits, in particular: First, the amount of time MSSP ACOs may linger in upside-only tracks shouldn't be cut from six years to two years, as proposed; second, the shared savings rate shouldn't be cut from 50% to 25%, as proposed.

The organizations argue in their letter that ACOs have been an important part of the shift toward value-based care through clinical and operational transformations alike but that such initiatives need time to mature into their full potential.

"These transformations are significant and, as such, require time for implementation and to produce measurable results," the letter states.

That sentiment echoes both the finding of analysis released this week by Avalere and the conclusions reached by CMS in a notice of proposed rulemaking last month.

What's more, a majority of the ACOs currently in the program indicated they would be at least somewhat likely to leave MSSP if they were required to take on downside risk, according to a NAACOS survey. In that context, the proposal to cut shared savings—which is the amount MSSP ACOs receive when they hit their targets—is especially disconcerting, the letter argues.

"The MSSP remains a voluntary program, and it's essential to have the right balance of risk and reward to continue program growth and success," the letter states. "Program changes that deter new entrants would shut off a pipeline of beginner ACOs that should be encouraged to embark on the journey to value, which is a long-standing bipartisan goal of the Administration and Congress and important aspect of the Quality Payment Program."

When the proposed changes were announced last month, CMS Administrator Seema Verma explained the rationale in a Health Affairs blog post.

"The results show that ACOs that take on greater levels of risk show better results for cost and quality over time," Verma wrote. "Our approach generally is to reward providers with more flexibilities as they take on increasing accountability for spending; to engage and incentivize beneficiaries to achieve and maintain good health; and to reduce gaming.  As providers assume greater levels of risk, CMS aims to provide them with greater flexibility to innovate and deliver high-quality care."

The eight additional organizations that signed onto the letter with NAACOS were the Association of American Medical Colleges, the American College of Physicians, America's Essential Hospitals, America's Health Insurance Plans, the American Medical Association, the Health Care Transformation Task Force, the Medical Group Management Association, and Premier.

Letter of Support for ACOs and MSSP NPRM Sign on 09202018 by HLMedit on Scribd

Steven Porter is an associate content manager and Strategy editor for HealthLeaders, a Simplify Compliance brand.


Given the program's voluntary status, it's important that CMS strike a balance between risk and reward, the organizations argue.

When the 2019 changes were proposed, Verma suggested that striking a proper balance would include ACOs taking on more risk.

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