HCTTF Writes to CMS Recommending Improvements to the Medicare Shared Savings Program

The Health Care Transformation Task Force wrote a letter to the Director of the Center for Medicare, Dr. Meena Seshamani, encouraging CMS to leverage the Medicare Shared Savings Program (MSSP) to further advance provider adoption of Alternative Payment Models (APM) across the U.S. The letter includes recommendations for modifying policies to make the program more accessible for new participants, providing additional flexibilities within MSSP to improve program sustainability for existing participants, and using MSSP as a testing platform for new Center for Medicare and Medicaid Innovation (CMMI) model concepts.


  1. CMS should make MSSP more accessible for new participants by increasing the percentage of shared savings available across all participation tracks.
  2. CMS should improve the sustainability of the program for existing participants by:
    • Creating a full risk track for advanced Accountable Care Organizations (ACOs)
    • Modifying risk adjustment and benchmarking to better reflect the factors participants encounter in the delivery of care including the social determinants of health and community level factors impacting care
    • Eliminating the high and low revenue ACO distinction created under the Pathways for Success program
    • Updating the MSSP benchmarking methodology so participants aren’t competing against their own successes in providing better care
    • Creating a glide path to expanded quality reporting
    • Allowing participants to use TIN/NPI enrollment
    • Working to improve Medicare beneficiary awareness of ACOs and allow for waivers to increase affordability.
  3. CMS should leverage MSSP as a platform for innovation by using it as a test bed for new CMMI ACO model concepts.

Read the Letter