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MSSP Flexibility Vital to Future of Value-Based Care

Analysis  |  By Debra Shute  
   April 07, 2016

Proposed changes to the fledgling Medicare Shared Savings Program would create a path for growth of the ACO model, but there's more work ahead.

Proposed changes to the Medicare Shared Savings Program (MSSP) would create steps toward the program's growth, but the Center for Medicare & Medicaid Services has more work ahead to refine the ways it will benchmark performance going forward.

Failure to do so could snuff the life out of the fledgling MSSP program, which includes fewer than 500 total members, but represents nine out of every 10 ACOs.

That's the claim of 22 organizations, including the American Medical Association, Medical Group Management Association, American Medical Group Association, American College of Physicians, and various specialty societies that signed a joint letter to CMS Acting Administrator Andy Slavitt on March 25.

Although the groups support the transition to regional benchmarks, they asked CMS to revisit several details. "While we recognize and appreciate CMS's efforts in this notice of proposed rulemaking to improve program methodologies to retain and attract [accountable care organizations] ACOs, we emphasize the critical need for the agency to further modify the program to address other critical issues such as quality measurement, risk adjustment and unstable assignment to ensure a successful future for this program," they write.

Expansion from One-Size-Fits-All
If CMS takes these comments to heart, the implications would be substantial, according to Suzanne Falk, MGMA associate director of government affairs.

"The program right now just isn't having the kind of numbers behind it to justify expanding it, which is what CMS is trying to do as we move toward an alternative payment model environment," she says. In 2014, about a quarter of Track 1 ACOs earned shared savings, she notes, and nearly half generated losses.

"These benchmarking changes are really critical and they do definitely improve by incorporating in those regional cost data, creating a more accurate picture. But they're still sticking with kind of that one-size-fits-all approach that misses the mark. And because the program is voluntary, we really need that to be flexible in order to attract new and different types of ACOs," Falk says.

The abridged recommendations of the MGMA and other groups to CMS include the following:

  • Finalize, with modification, blending ACO historical and regional cost data into ACO benchmarks
  • Provide ACOs with maximum flexibility and choices related to transitioning to benchmarks that comprise a component of regional cost data
  • Focus on comparing ACO performance relative to fee-for-service Medicare by excluding ACO assigned beneficiaries (for all ACOs in the region) from the regional beneficiary population
  • Honor the current policy that accounts for savings in rebased benchmarks, rather than punish ACOs that worked hard to earn savings in previous agreements
  • Modify and enhance the proposal to reopen ACO determinations to include greater opportunities for ACOs, especially when CMS errors are the cause, and shorten the timeframe from four to two years

Overall, these requests urge CMS to be less aggressive and more flexible in the way it implements new benchmarks. Because of the considerable investment of time and money involved in becoming an ACO, medical groups need assurance that the effort will be worthwhile.

Debra Shute is the Senior Physicians Editor for HealthLeaders Media.

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