AHA urges 5 major changes to proposed MSSP rule

The American Hospital Association (AHA) urged the Centers for Medicare & Medicaid Services to make major changes to its proposed rule for the Medicare Shared Savings Program (MSSP) and offer participants more rewards and less risk for taking part in the accountable care organization program.

The proposed rule provides ACOs participating in the program with an additional three years before they receive penalties for poor performance. 

While AHA Executive Vice President Rick Pollack welcomed CMS' proposed changes, he wrote that the AHA "question[s] whether other proposals go far enough to correct misguided design elements that emphasize penalties rather than rewards." The AHA has also said the proposed rule put too many restrictions on patient transportation, FierceHealthFinance previously reported.

The current proposal, Pollack wrote, offers MSSP members and potential members excessive risk and burden for insufficient payoffs. CMS should bear in mind, Pollack wrote, the amount of time, resources and energy providers have already invested in developing operational and clinical resources for patient care management, and amend the shared savings determination to allow a greater number of ACOs to benefit from the shared savings.

"This will allow them to continue to invest in the program and give ACOs adequate tools to coordinate and manage care," he wrote.

The AHA also recommends:

  • Offering better risk-reward balance that encourages ACOs to assume more risk but does not punish those that require more time and experience with MSSP
  • Altering the assignment process for Medicare beneficiaries to emphasize primary care options
  • Changing the existing benchmark methodology to keep ACOs from being forced to compete against their own best performances
  • Creating a "rapid response" system to ensure improved, more efficient data for ACO use

Leading health economist Paul Keckley, managing director of the Navigant Center for Health Policy Analysis, has similarly criticized the proposed rule for not going far enough, telling FierceHealthcare it "[doesn't] address some of the things that the ACOs are currently participating would like to have seen."

To learn more:
- read the letter (.pdf)