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Twenty physician organizations and other healthcare groups, including the American Medical Association, have submitted joint comments to the Centers for Medicare and Medicaid Services praising the agency for some of its changes but say there is room for improvement in a proposed rule regarding Accountable Care Organizations in the Medicare Shared Savings Program.
The groups want CMS to honor the current policy that accounts for savings in rebased benchmarks, rather than punishing ACOs that worked hard to earn savings in previous agreements.
They asked CMS to enhance the proposal and reopen ACO determinations to include greater opportunities, especially when CMS errors are the cause. They also proposed shortening the timeframe from four to two years.
In their comments, the signers expressed strong support for CMS's proposal to incorporate regional cost data into benchmarks. The current method of basing benchmarks solely on historical spending penalizes ACOs for performing well in the past, they said, and forces them to chase increasingly more challenging benchmarks.
By blending historical and regional cost data, CMS will improve the long-term viability of the program by attracting new providers, while also enhancing the odds of retaining current participants, they said.
However, they want CMS to provide ACOs with maximum flexibility when it comes to transitioning to regional benchmarks and also to focus on comparing performance for fee for service Medicare by excluding the ACO population in the area.
"Given our analyses show ACOs on average spend three percent less than comparable fee-for-service expenditures, it should remain a priority of the Secretary to refine the model in ways that will promote further program growth," the signers told CMS Acting Administrator Andy Slavitt.
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The joint comments represent the collective views of organizations representing physicians, hospitals, medical group practices, academic medical centers and nearly all existing Medicare Shared Savings Program ACOs.
Separately, although not addressed in the proposed rule, the commenters also said that as CMS heads into rulemaking for the Medicare Access and CHIP Reauthorization Act the agency should designate all MSSP ACOs as qualifying alternative payment models under MACRA.
This would allow physicians participating in all MSSP ACOs to qualify for MACRA APM incentive payments, provided they meet the threshold levels of revenue or patient participation required by the law, they said.