A multi-organizational response to CMS’s proposed physician fee schedule seeks to generate strong program savings but stable participation growth.
The National Association of ACOs (NAACOS) is calling for the strongest responsible care design possible, as the program demonstrates significant annual savings and quality.
In a comment letter to CMS’ Proposed Physician Fee Schedule for 2023the association and 10 other vendor groups cited the following rule components, expressing support for some and modifications for others.
As summarized in the ANACO press release“The settlement, if finalized, would make several positive changes to [MSSP] …including giving ACOs more time before reaching the highest levels of risk, providing fairer and more accurate financial benchmarks, making positive changes to quality scoring approaches and providing prepayments shared savings to smaller ACOs that serve underserved populations.
- Ongoing and expanded funding
Launching and sustaining successful value-based models of care (VBC) requires significant funding. As such, the NAACOS Group letter supports advance payments to all ACOs with health equity goals. The group also wants the incentive payments to continue for Quality Payment Program participants who are part of Advanced Alternative Payment Models. The 5% annual bonus expires in 2022 and can only be renewed by legislation. House Democrats introduced the Value in the Health Care Act in July 2021 to extend the incentive program while making other changes to the MSSP.
- Greater stakeholder voice and flexibility on ACO benchmarks
Support for the CMS benchmark changes ranged from the NAACOS group, with their letter applauding administrative benchmarks to support reimbursement and health equity, but wanting stakeholders to have adequate opportunities to shape these changes and participate in it in a timely manner.
Related: Medicare Shared Savings Program Saves Over $1.6 Billion With ACOs
- Retooling ACO definitions
The NAACO letter asks CMS to eliminate the identification of high-income and low-income ACOs, noting that these distinctions are arbitrary (e.g., federally qualified health centers, rural health clinics, and safety-net hospitals are considered high-income) and should be made based on an ACO’s patient characteristics instead.
- 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 waivers in an era of public health emergencies.” In other areas, including electronic quality reporting, the group is urging CMS to slow down its timeline to ensure a smooth transition.
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 staff writer for HealthLeaders.