The Task Force Provides Input to CMS on Improving the Medicare Shared Savings Program

The Health Care Transformation Task Force submitted feedback to the Centers for Medicare & Medicaid Services (CMS) about policies that impact the Medicare Shared Savings Program (MSSP). The letter identifies opportunities to strengthen MSSP Accountable Care Organizations (ACOs) through the forthcoming CY2025 Physician Fee Schedule, including:

1. Risk Arrangements & Benefit Enhancements: CMS should create additional incentives to experienced ACOs by offering three things: (1) greater ACO opportunity for reward and accountability for risk based on costs and quality, (2) additional financial flexibilities to support ACO investment in care transformation, primary care, and health equity, and (3) expanded benefit enhancements to allow ACOs flexibility in how they address patient needs.

2. Benchmarks: CMS should adopt policies that address the “ratchet effect” experienced by ACOs, in which prior savings result in shrinking benchmarks. ACOs experience two forms of ratcheting, first during the agreement period—which CMS has adopted policies to mitigate—and secondly, when a new contract is signed. HCTTF proposes an updated methodology to account for prior savings and to reward participants for achieving previous savings, while still delivering CMS savings.

3. Quality Payment Program (QPP): The QPP program was designed in part to create non-financial incentives for ACOs and other providers to bear financial risk, such as reduced reporting burdens. However, several recent regulatory actions have increased the reporting burden for these providers. In particular, the forthcoming electronic Clinical Quality Measure (eCQM) reporting requirements are difficult to comply with and do not necessarily produce high-quality data for CMS. HCTTF recommends that CMS adopt several regulatory changes to smooth the transition to eCQMs and retain these key non-financial incentives for ACO participation.

4. Health Equity: HCTTF fully supports CMS’ efforts to promote alignment between ACOs (and other APMs) and community-based organizations (CBOs). A central goal of ACO models is to drive fundamental improvements in population health, yet the tools necessary to accomplish this often exist outside of clinical care settings. HCTTF recommends that CMS support standardized data collection for health equity, incorporate this data into payment methodologies, and support efforts to streamline partnerships with CBOs.

5. General Model Design: HCTTF shared a new recommendation for CMS to better support ACOs that primarily serve institutionalized beneficiaries by updating the quality measures and risk adjustment to more accurately reflect these patients’ needs. In addition, HCTTF reiterated several standing concerns about MSSP model design, including the need to remove the revenue distinctions between ACOs, streamline the attribution process, and support engagement by high-value specialists by providing data and allowing ACOs to select the providers in their network.


Read the Letter Here