Provider groups had plenty to say about the proposed changes to the Medicare Shared Savings Program (MSSP) that are likely to drive out a portion of accountable care organizations (ACOs) if finalized.
A new survey by the National Association of ACOs (NAACOS) released this week shows that 60% of ACOs currently in the MSSP wouldn’t enter the program under the proposed structure, which includes reducing shared savings from 50% to 25% and shortening the amount of time ACOs can remain in a one-sided risk model from six years to two years.
Nearly half of the ACOs surveyed said they are likely to continue even if those changes take effect. More than one-third (36%) said they were unlikely to continue under the proposed structure, and 16% took a neutral stance.
The results came months after a similar NAACOS survey that said most ACOs would leave the program if they were required to take on more risk.
Overall, 61% of ACOs surveyed opposed the proposed rule, primarily because it reduces the shared savings rates and requires organizations to take on more risk sooner.
NAACOS highlighted those results in comments (PDF) to the Centers for Medicare & Medicaid Services (CMS) this week. The organization provided a list of 14 key recommendations that included a “more gradual ramp up” from Track 1 ACOs to two-sided risk models and a shared savings rate as high as 60% for some tracks.
The proposed changes elicited significant handwringing from organizations like NAACOS, while others welcomed the shift.
“NAACOS believes that ACOs should take on risk,” President and CEO Clif Gaus said in a statement. “But the speed of CMS’ proposed path to risk and the agency’s proposal to significantly cut financial incentives will make participation in this voluntary program untenable for new ACOs."
The Health Care Transformation Task Force (HCTTF) made similar pleas, arguing that giving ACOs a longer leash will lead to more participation and that the share savings reduction may not provide sufficient incentives for ACOs to take on more risk.
HCTTF also called on CMS to adjusted its benchmark methodology for calculating ACO savings arguing that it “underestimates true savings to the Medicare program.”
Indeed, recent data from NAACOS show that ACOs saved Medicare $1.8 billion between 2013 and 2015, nearly twice as much as CMS estimates. CMS’ own data show the program saved $314 million in 2017, with the bulk of that coming from Track 1 ACOs.
Meanwhile, the American Academy of Family Physicians proposed a three-year glide path for new one-sided ACOs. But the organization urged CMS to maintain the shared savings rate at 50% and requested that CMS extend existing agreements through 2019 and initiate new changes beginning in 2020.
“With a proposed July 1, 2019, start date, CMS is creating two six-month performance years, which adds an additional layer of complexity and confusion,” the organization wrote (PDF). “Delaying the start until 2020 will give new ACOs adequate time to form and review the participation criteria."