Major healthcare systems are praising the CMS' attempts to make Medicare's biggest accountable care program more attractive as the agency strives to grow the number of participants while also persuading more of them to assume greater financial risk.
In January, the agency proposed overhauling the way it evaluates if and how much money accountable care organizations are saving in the Medicare Shared Savings Program (MSSP). Under the revised methodology, for example, the agency would adjust cost benchmarks based on regional rather than national spending data when an ACO signs up for a second three-year contract period.
This change and other tweaks seek to address complaints that the benchmarks don't allow efficient providers to earn substantial bonuses.
The agency received 74 comments before the March 28 deadline.
“Such a policy change is critical to attract greater participation in the program, to retain existing participants, and help move more ACOs to risk-sharing agreements," Trinity Health, a Livonia, Mich.-based Catholic health system with national reach, said in a comment letter.
Dignity Health, another large not-for-profit health system, said the changes, “if executed correctly,” could attract new participants and improve the long-term viability of the program.
The Affordable Care Act catalyzed the creation of Medicare ACOs, which are networks of hospitals and physicians that aim to improve the quality and lower the cost of care for Medicare beneficiaries in a defined area. As of January 2016, there were 434 ACOs participating in the shared-savings program, serving more than 7.7 million beneficiaries.
ACOs that entered the program in 2012 or 2013 wouldn't be eligible for the new methodology until their third contract period. Trinity said the CMS should allow participants that renewed their contracts in 2016 to be given the option to move toward regional benchmarks without having to wait.
“More than any other cohort, these early adopters deserve this option and we see no significant rationale for their exclusion,” Trinity said in its letter. “These ACOs should not be penalized simply because of unfortunate timing.”
Others asked for changes that go beyond the benchmarks.
Catholic Health Initiatives complained that Medicare provides ACOs with large quantities of data and little guidance on how to use it, leaving providers to rely on consultants to understand the information and its potential financial impact.
“We think CMS could take on a greater role in this area by developing robust financial modeling tools and distributing it to the ACOs directly,” CHI said. “Not only would this save ACOs money, and thus save Medicare money, by eliminating the need for expensive consultants, it would level the playing field for smaller ACOs trying to navigate MSSP.”
CHI said better tools for understanding the data might also help the CMS achieve its goal of persuading more of the program's participants to accept what's known as two-sided risk—meaning they could be penalized for falling short of the benchmarks in addition to earning bonuses for beating them.
Of 434 ACOs participating in the program, only 22 have chosen to participate in tracks that include downside risk.