AAMC Feb. 6 submitted a comment letter and joined two letters to the Centers for Medicare and Medicaid Services (CMS) on the Medicare Shared Savings Program (MSSP) proposed rule. MSSP are a form of payment reform that allows Medicare to share savings if an Accountable Care Organization (ACO) meets certain quality and savings targets.
While the joint letters provide a set of recommendations from a broad group, including various physicians, hospitals, and MSSP representatives, the AAMC submitted its own letter that focuses on MSSP policies as they affect teaching hospitals and faculty practices, as well as the unique patients they serve.
The recommendations in the joint letters focused on several themes, including: improving the assignment of the patient population, suggesting modifications to the MSSP business model (the amount at risk and the amount of savings that is shared) to promote flexibility and reward quality, recommending broader access to waivers to improve care redesign, as well as other commenting on other aspects of the program.
The AAMC individual comment letter echoed several of the joint letter recommendations, including:
- Continuation of a one-sided risk model in MSSP without lowering the sharing rate. Almost all of the existing MSSP ACOs are currently one-sided.
- Implementation of an attestation process to ensure that non-physicians who are included in the first step attribution methodology provide primary care.
- The continued exclusion of policy add-on payments (e.g., indirect medical education and disproportionate share hospital payments) from MSSP benchmarks and other financial calculations.
- Having a prospective attribution option for all tracks; not just the most advanced track.
- Expanded use of waivers to provide ACOs the tools to redesign care.
The joint stakeholder letters to CMS that AAMC endorsed are available here and here.