The Facilities for Medicare and Medicaid Providers ought to remove the excellence between high- and low-revenue accountable care organizations, teams representing healthcare suppliers wrote in remark letters on a current regulatory proposal.
Suppliers additionally want to see CMS allow present ACOs to decide into benchmarking modifications beginning in 2024 and make different tweaks to the proposed Medicare Shared Financial savings Program overhaul.
CMS unveiled main modifications to the Shared Financial savings Program, its everlasting accountable care group initiative, as a part of its draft doctor price schedule rule for subsequent 12 months.
Suppliers are usually supportive of CMS’ plans, which embody insurance policies that might give ACOs extra time to transition into performance-based danger preparations.
“We applaud CMS for taking motion to not solely help progress within the [Medicare Shared Savings Program] but additionally to handle a number of well-known points in this system which have made it difficult for ACOs to proceed participation,” Premier, which operates ACOs for its members, wrote.
Many supplier teams additionally again CMS’ proposal to provide new ACOs superior shared financial savings funds to jumpstart their operations. However ACOs might solely reap the benefits of these funds in the event that they’re thought-about low-revenue.
Since 2018, ACOs have been divided into two classes primarily based on income. Excessive-revenue ACOs theoretically have extra management over spending per beneficiary, so CMS believes they need to be capable of tackle extra monetary danger. ACOs with hospital members are sometimes thought-about high-revenue.
A CMS truth sheet on the draft rule specifies that the company expects the superior fee proposal to draw extra suppliers from rural and different underserved areas. However value-based care advocates consider making use of the income standards to this proposal could be counterproductive.
The Nationwide Affiliation of Accountable Care Organizations, which all the time has opposed the income distinction, maintains that CMS ought to toss the idea altogether. “CMS ought to as a substitute think about different approaches, comparable to evaluating the demographics of the inhabitants served by an ACO. The excessive/low income standing is bigoted and leaves out the very ACOs CMS is attempting to draw to this system,” the group wrote.
ACOs with group well being facilities, rural well being clinics and important entry hospitals are extra generally labeled as high-revenue, in accordance with NAACOS so that they ACOs wouldn’t profit from the revised insurance policies.
Different events together with Premier, the American Hospital Affiliation and the Medical Group Administration Affiliation additionally ask CMS to increase the {qualifications} for superior funds past the income distinctions.
“[I]t is necessary that every one new-entrant ACOs interested by taking part in this system have entry to this superior fee pathway to help participation in [the Medicare Shared Savings Program] as a mechanism to assist handle well being fairness and increase the Medicare beneficiary inhabitants served by enrolled suppliers,” the Medical Group Administration Affiliation wrote.
However it seems unlikely the company will dispose of the high- and low-revenue distinction. The present proposal might even be considered as a compromise between CMS and suppliers, stated Lauren Cricchi, a guide at Avalere Well being. Sure insurance policies, such because the prolonged danger pathways, apply to ACOs no matter income standing.
“I do not see them eliminating the designation,” Cricchi stated. “They’re including these further insurance policies that require that type of designation…however I do see this as probably assembly within the center between what had been advocated for and what CMS is attempting to perform.”
Suppliers additionally commented on CMS’ different plans for the Shared Financial savings Program, together with modifications to the ACO benchmarking methodology. ACOs might share in financial savings once they spend beneath an assigned benchmark, which relies on prices in baseline years and on spending progress. Underneath the present system, ACOs that enhance financial savings every year confront benchmarks which can be more and more tougher to exceed as a result of they’re reset primarily based on previous outcomes.
CMS proposed altering the strategy for updating the historic benchmark to incorporate a potential exterior issue, including a previous financial savings adjustment for returning ACOs and lessening the consequences of a adverse regional adjustment.
Supplier teams usually help the hassle to repair benchmarking however recommend some additions, comparable to permitting ACOs to decide on pre-COVID-19 years as benchmarks.
Trade teams additionally emphasize CMS ought to let ACOs already taking part within the Shared Financial savings Program decide into a number of the monetary modifications beginning in 2024. In response to the Nationwide Affiliation of Accountable Care Organizations, 43% of taking part ACOs wouldn’t see advantages till 2027, whereas new entrants would get pleasure from improved benchmarking immediately.
CMS allowed ACOs to maneuver into a brand new construction possibility in 2019 by modifying program contracts, an strategy that might additionally work on this occasion, the Nationwide Affiliation of Accountable Care Organizations wrote.