A multi-organization response to CMS' proposed Physician Fee Schedule seeks to build off strong program savings but flat participation growth.
The National Association of ACOs (NAACOS) is calling for the strongest possible accountable care design as the program posts significant annual savings and quality.
In a comment letter to CMS' proposed 2023 Physician Fee Schedule, the association and 10 other provider groups called out the following rule components—expressing support for some and changes to others.
As summarized in the NAACO press release: "The regulation, if finalized, would bring several positive changes to [MSSP] … including giving ACOs more time before advancing to the highest levels of risk, providing fairer, more accurate financial benchmarks, making positive changes to quality scoring approaches, and providing advance shared savings payments to smaller ACOs that serve underserved populations."
- Continued and expanded funding
Launching and maintaining successful value-based care (VBC) models requires significant funding. As such, the NAACOS group letter supports advanced payments to all ACOs with health equity objectives. The group also wants to see incentive payments continue for Quality Payment Program participants that are part of Advanced Alternative Payment Models. The annual 5% bonus expires in 2022 and can only be renewed via legislation. House Democrats introduced the Value in Health Care Act in July 2021 to extend the incentive program while making other MSSP changes.
- Greater stakeholder voice and flexibility on ACO benchmarks
Support for CMS benchmark changes is varied from the NAACOS group, with their letter applauding the administrative benchmarks to support reimbursement and health equity but wanting stakeholders to have adequate opportunities to shape these changes and participate in them in a timely way.
- Retool ACO definitions
The NAACOs letter calls for CMS to eliminate the identification of high and low-revenue ACOs, noting that these distinctions are arbitrary (e.g., Federally Qualified Health Centers, Rural Health Clinics, and safety-net hospitals are considered high revenue) and should be made instead based on an ACO's patient characteristics.
- Innovation, fast and slow
CMS wants 100% of original Medicare beneficiaries to be in VBC by 2030. This will require continued innovation. The NAACOS group letter urges the agency to use "MSSP as an innovation platform … 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-era waivers." In other areas, including electronic quality reporting, the group urges CMS to slow its timeline to ensure a smooth transition.
The organizations that signed the letter, in addition to NAACOS, included: 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, the National Rural Health Association, and Premier, Inc.
Laura Beerman is a contributing writer for HealthLeaders.