The American Medical Group Association and the American Hospital Association issued responses to CMS' proposed changes to the Medicare Shared Savings Program and made various recommendations to the agency.
Eight notes:
1. CMS issued a proposed rule Aug. 9 revising the Medicare Shared Savings Program, a voluntary accountable care organization initiative.
2. The AMGA, in an Oct. 16 letter to CMS about the proposed rule, recommended that CMS "improve program benchmarking to correct for current weak financial incentives" and stop using historical spending in resetting subsequent agreement period benchmarks. Instead, the group said CMS should update benchmarks annually after the first performance period.
3. The AMGA also recommended extending the time providers participating in the proposed ACO basic track can remain in an upside-only risk agreement to three years. Under CMS' proposed rule, basic track ACOs can participate under an upside-only agreement for one to two years before gradually taking on greater financial risk.
4. The AMGA said CMS' proposal to terminate an ACO from the program if it falls outside the negative minimum savings rate or minimum loss rate corridor is "an unnecessary provision, as ACOs in the proposed glide path will assume financial risk."
5. The AHA expressed concerns over CMS' proposed rule, saying, "as a whole, the proposals in the rule would likely result in significant decrease in MSSP participation."
6. The AHA, in its own Oct. 16 letter to CMS, recommended CMS not finalize the proposed differentiation of participation options for high- and low-revenue ACOs. Rather, the AHA recommended improving MSSP methodology "to accurately reward performance for improving quality and reducing costs and offer resources and assistance to all ACOs."
7. The AHA said CMS should allow new, inexperienced ACOs to remain under an upside-only agreement for three years instead of the two proposed.
8. The AHA recommended CMS expand access to the skilled nursing facility three-day rule waiver and telehealth coverage through waivers and recommended changes to benchmarking methodology.
Access the AMGA's full letter here and the AHA's full letter here.
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