A dozen medical groups and healthcare organizations are calling on the Biden administration to delay and make significant changes to the way accountable care organizations report and are measured on quality.
In a letter to Department of Health and Human Services Secretary Xavier Becerra, the American Medical Association (AMA), the American Hospital Association (AHA), and America’s Physician Groups, among others, said they had "significant concerns" about the Medicare Shared Savings Program (MSSP) quality policies finalized at the very end of 2020.
The groups cited concerns about rushed implementation, still unanswered questions on changes, and potential negative consequences to patient care.
If changes are not made soon, ACOs and their participants will bear significant health information technology costs and upgrades to be able to collect and report data, the groups said in the letter.
ACOs also may drop clinicians, particularly specialists or small practices because of additional reporting burdens and IT costs, or ACOs could drop out of the program altogether, according to the letter, which was also signed by the American Academy of Family Physicians (AAFP), American College of Physicians, AMGA, America’s Essential Hospitals, the Association of American Medical Colleges, Federation of American Hospitals, Medical Group Management Association, and the National Association of ACOs.
"The policy changes lacked adequate input from the patient, ACO, physician and hospital communities, and it is unclear how the Center for Medicare & Medicaid Services (CMS) determined that the Alternative Payment Model Performance Pathways (APP) measures are more appropriate than the current measures on which ACOs are evaluated," the groups said in the letter.
In August, the Trump administration proposed the 2021 Medicare payment rates for physicians, which included changes to the Merit-based Incentive Payment System. That rule (PDF) was finalized in late December.
The 2021 Medicare Physician Fee Schedule finalized a move to electronic quality measures for ACOs, among other changes. The move requires ACOs in the MSSP to aggregate data from disparate electronic health records (EHR) systems, which are not interoperable, and report on quality data on all patients regardless of payer, raising issues with collecting data from non-ACO providers and on patients with no connection to the ACO, the groups stated in the letter.
The move could also widen health disparities as ACOs’ quality performance could be misrepresented as differences in quality when variation is likely due to patient access to care or complexity, the groups wrote in the letter.
“ACOs treating vulnerable populations have a different mix of payers and patients, which will cause them to appear to have lower quality,” the letter states. “This will reduce their shared savings at a time they should be receiving more resources to combat health equity issues and more support to remain on the path to value.”
The changes also ignore the time it takes to adopt and implement electronic measures. "Therefore, key policy changes and additional time are needed to ensure that ACOs can participate successfully, and that patient care is not negatively impacted," the letter states.
Based on input from ACOs, the groups outlined a number of recommended changes including delaying the mandatory reporting of eCQMs and MIPS CQMs for at least three years and limiting ACO reporting to ACO-assigned beneficiaries only, rather than all patients across payers.
The groups also recommend that CMS clarify and establish quality performance benchmarks in advance for all ACO reporting options and also are calling for CMS to retain pay-for-reporting when measures are newly introduced or modified.
“To start 2021, 477 ACOs are participating in the MSSP, down from a high of 561 in 2018 and the lowest since 480 participated in 2017. The program is further threatened by these quality changes,” the letter stated. “We request CMS correct the flawed MSSP quality overhaul as an early step towards strengthening the MSSP and the overall shift to value in Medicare.”