Dive Brief:
- The American Hospital Association (AHA) has provided the CMS with recommendations regarding the proposed changes to the Medicare Shared Savings Program (MSSP). The AHA says suggests that more can be done to draw participation of accountable care programs and to reduce the burdens on accountable care organizations.
- "While some of CMS's proposed improvements are welcome and could make the program more attractive to new applicants and existing ACOs, we question whether other proposals go far enough to correct misguided design elements that emphasize penalties rather than rewards,"
the letter states. As currently proposed, the MSSP applies too many "sticks" and offers too few "carrots," the AHA says. - The AHA asks the CMS to "modify the shared savings determination so that more ACOs can share in more of the savings they generate," which would allow them to continue to invest in the program and to access adequate tools to coordinate and manage care.
Dive Insight:
The AHA makes 5 specific requests that could help create incentives for MSSP participation. As the organization notes, it will be necessary for the CMS to attract and maintain long-term ACO participation to meet Secretary Burwell's goal of tying 30% of fee-for-service Medicare payments to alternative payment models by the end of 2016, and to increase that amount to 50% by 2018.
The AHA's requests include:
- Balancing the risk/reward equation in such a way that ACOs are encouraged to assume additional risk without penalizing ACOs that need "additional time and experience with the MSSP" before they are able to take on additional risk.
- Modifying the assignation of Medicare beneficiaries to put the focus on primary care and give ACOs assignment options "allow[s] them to better identify and target services to those beneficiaries for whose care they will be held accountable."
- Implement payment waivers, like the skilled nursing facility three-day stay rule, telehealth payment restrictions and the two-midnight rule, that would open up care coordination opportunities.
- Adjust the benchmark methodology to both account for regional cost differences and "ensure that an ACO does not have to compete against its own best performance."
- Create a "rapid response" system that gives ACOs timlier and better data to assist in care coordination efforts.
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