The American Hospital Association has submitted comments to CMS suggesting changes to be made to the Pioneer Accountable Care Organization Model and the Medicare Shared Savings Program.
In the letter, the AHA commented that the current Pioneer ACO program and the MSSP "place too much risk and burden on providers with too little opportunity for reward in the form of shared savings," and outlined changes to be made to the Pioneer ACO Model and the MSSP to attract more participation.
Regarding the MSSP, the AHA highlighted that CMS has put in place "extremely complicated and onerous provisions in order for ACOs to receive beneficiary-level data for their assigned population," and commented the provisions serve as a deterrent to joining ACOs. The AHA stressed how important it is for ACOs to know its aligned beneficiaries on a monthly basis, and commented that "timely Medicare claims data is necessary to obtain a complete picture" of the care beneficiaries are receiving outside and inside the ACO.
To help with the patient attribution issue, AHA recommended CMS implement a voluntary sign up process that would allow Medicare beneficiaries to opt-in to receiving care in an ACO model because it would provide clarity as to the Medicare beneficiaries for which the ACO is responsible.
The AHA noted the 114 MSSP ACOs that launched in 2012 show a $128 million savings for the Medicare program. However, only 27 of the 114 MSSP ACOs were able to qualify for shared savings in the first year of the program. The AHA suggested the risk versus reward equation needs to be adjusted "to ensure more ACOs are able to receive a bonus — and a larger bonus — so they can continue to invest in the program." To achieve this goal, the AHA suggested the following:
- Extending the track 1 agreement period to six years
- Holding all MSSP ACOs accountable to a standard minimum savings rate of no more than 2 percent, regardless of the number of attributed beneficiaries
- Creating a more achievable financial threshold in the early years, even if it means setting a more difficult threshold in later years
- Implementing technical adjustments to the benchmark to account for policy changes outside of the providers' control
Regarding the Pioneer ACO Model, the AHA recommended creating several options for practitioners to move from fee-for-service to managing the health of a population, such as partial capitation for certain services or certain beneficiaries, like those with multiple chronic conditions. "Providers need options along a spectrum" to move away from fee-for-service payments, the letter stated.
The AHA also urged CMS not to require Pioneer ACOs to establish significant financial reserves because providers may "prefer to reinvest earnings in care delivery" to improve patient outcomes and care coordination. Rather than establishing the financial reserves, the AHA recommended CMS require Pioneer ACOs to generate a set level of savings in the previous years to qualify to elect population-based or full-risk payment.
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