Healthcare Orgs Request Medicare Shared Savings Program Updates in PFS

Healthcare groups, including the American Medical Association (AMA), have asked CMS to consider additional updates to the Medicare Shared Savings Program (MSSP) before finalizing the Medicare Physician Fee Schedule (PFS) for calendar year 2023.

The proposals included in the PFS aim to increase provider participation in accountable care organizations (ACOs).

In a letter to CMS Administrator Chiquita Brooks-LaSure, the organizations supported the proposed changes but offered several recommendations to improve ACO access and participation.

Other letter signatories included America’s Essential Hospitals, American Academy of Family Physicians, 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 Health Association, and Premier healthcare alliance.

The PFS introduced a proposal to provide advanced shared savings payments to certain new ACOs that focus on rural and underserved populations. AMA asked CMS to consider additional opportunities for ACOs to participate in advanced investment payments.

Expanding eligibility for advanced investment payments to all ACOs working to improve health equity would help reduce disparities and increase access to accountable care for underserved individuals, AMA said.

The PFS also proposed allowing new ACOs to participate in upside-only risk-sharing models for up to seven years before taking on downside risk. AMA supported this proposal but urged CMS to eliminate the high and low revenue distinction that penalizes certain providers within this glidepath. Instead, CMS should offer benefits to ACOs based on beneficiary characteristics.

The ACO updates only apply to ACOs with new agreements starting in 2024. AMA requested that CMS allow existing ACOs to participate in the new payment approaches by amending their current contracts.

In response to CMS requesting feedback on administrative benchmarks, the healthcare organizations asked that the agency engage stakeholders in designing benchmarks for the future to ensure ACOs are not penalized by certain guidelines.

The letter also raised concern about the electronic clinical quality measure (eCQM) updates. While CMS removed the current all-or-nothing approach used to determine if an ACO is eligible for shared savings based on quality performance, the agency did not address the timeline for ACOs to report eCQMs. CMS did not adjust the all-payer approach associated with eCQM reporting either.

AMA urged CMS to reconsider these policies and run a pilot program to resolve the consequences of all-payer and eCQM reporting.

AMA also encouraged the agency to work with Congress to extend MACRA’s  5 percent Advanced Alternative Payment Model (APM) incentive payments.

Finally, the letter suggested that CMS consider ways to adapt the MSSP to continue to advance value-based care. For example, the CMS Innovation Center should test model innovations with MSSP to allow MSSP ACOs to take advantage of the enhanced flexibilities offered in Innovation Center models.

The National Association of ACOs (NAACOS) also submitted comments to CMS regarding the MSSP changes. NAACOS supported providing all ACOs addressing health equity with advanced shared savings payments and eliminating the revenue distinction for the risk updates.

NAACOS also urged CMS to finalize the inclusion of an additional, alternative quality performance standard that offers a more balanced approach to determining how quality scores contribute to shared savings opportunities for ACOs.

The organization encouraged the agency to modify the ACO benchmarks and avoid setting a national growth factor, as Medicare spending varies by region.

“An ACOs’ success can’t be decided simply by its geography. Instead, CMS should use a regional update factor on which to base administrative benchmarks,” Clif Gaus, president and chief executive officer of NAACOS, said. “We greatly appreciate CMS’s efforts to address the ‘ratchet effect’ and look forward to continued collaboration with the agency to determine best approaches for administratively set benchmarks.”