HHS must not let COVID-19 derail accountable care organizations and value-based care, the AAFP and eight other groups told the agency in a May 14 letter.(2 page PDF)
"ACO physicians and hospitals are among those on the front lines treating patients and supporting their communities in the face of the pandemic," the letter said. And to make that contribution, they have diverted resources and funding, it added.
Financial relief for ACO participants affected by the pandemic, the groups said, is therefore needed to safeguard a climate in which the Medicare Shared Savings Program can "achieve the long-term sustainability necessary to enhance care coordination for millions of Medicare beneficiaries, lower the growth rate of health care spending and improve quality of care."
The groups were responding to a pair of interim final rules: CMS-1744-IFC(www.federalregister.gov) (Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency) and CMS-5531-IFC(www.federalregister.gov) (Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program). The rules were published in the Federal Register on April 6 and May 8, respectively.
The letter was sent to CMS Administrator Seema Verma, M.P.H. Among the Academy's co-signatories were the AMA, the American College of Physicians and America's Physician Groups. The AAFP continues to review the proposed rules and may make additional comments.
"While it is very important to protect ACOs that are harmed by the pandemic from losses, it is also critical to allow eligible ACOs to still earn shared savings for performance year 2020," the letter said.
To protect ACOs and ensure continued program success, the groups called on CMS to make four immediate policy adjustments.
- ACOs should be given the option to be protected from losses in exchange for a reduced shared-savings rate of no less than 40%. "Providing the flexibility of this option would prevent ACOs from quitting and maintain the savings they generate for Medicare," the letter said.
- The June MSSP deadline should be extended to allow voluntary termination (thereby avoiding financial losses) until at least Oct. 31, while requiring no more than 30 days' notice. "Given a potential resurgence of the virus this fall, it is imperative for CMS to provide ACOs with additional time and data to make an informed decision about their ACO participation," the groups wrote.
- "CMS should reverse its decision to cancel the 2021 MSSP application cycle," the letter said. "At a minimum, we urge CMS to implement an application period for an abbreviated participation year, beginning no later than July 2021, as the agency has previously done."
- ACO shared-savings payments and advanced alternative payment model bonuses should be paid as soon as possible. (Such bonuses have been a bone of contention for the Academy in the recent past.)
Implementing these recommendations, the letter said, "will help ensure the future of ACOs and value-based care overall."
"CMS must act now to retain physicians and hospitals who have committed to accountable care and the transition to value, especially those that have assumed high levels of risk."
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