Draft – Improvements to the Medicare Shared Savings Program

December XX, 2023

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201

RE: Improvements to the Medicare Shared Savings Program

Dear Administrator Brooks-LaSure:

The National Association of ACOs (NAACOS) appreciates the opportunity to provide our recommendations on changes to the Medicare Shared Savings Program that will help support the goal of all Medicare patients in an accountable care relationship responsible for total cost of care and quality by 2030. NAACOS represents more than 400 accountable care organizations (ACOs) in Medicare, Medicaid, and commercial insurance working on behalf of health systems and physician provider organizations across the nation to improve quality of care for patients and reduce health care costs. NAACOS members serve over 8 million beneficiaries in Medicare value-based payment models, including the Medicare Shared Savings Program (MSSP) and the ACO Realizing Equity, Access, and Community Health (REACH) Model, among other alternative payment models (APMs). Additionally, our members have participated in bundled payment models tested by the Innovation Center.

As CMS begins considering changes for the CY 2025 Medicare Physician fee schedule, we suggest that CMS prioritize the following three areas for improvements to the Medicare Shared Savings Program.

Address the benchmark ratchet. Over the next two years, the majority of MSSP participants will enter new contract agreements and have their benchmarks rebased and lowered due to achieving savings during the current contract cycle. While CMS has adopted policies to reduce the impact of the ratchet (i.e., prior savings adjustment, ACPT) these policies do not go far enough and many ACOs may face deep reductions to their benchmarks. It is critical that we ensure that ACOs have fair and accurate benchmarks. The savings achieved in these models directly impact patient care by expanding care teams, providing additional beneficiary services that are not billed to Medicare, ensuring provider retention with enhanced provider payment, and investing in technology or other services that enable care coordination and population health management. Lowering benchmarks because of the ratchet effect reduces providers’ ability to improve care and reduces the ACO’s opportunity to achieve success and reinvest shared savings into beneficiary care.
Remove burden from the program. To achieve greater movement to value, strong nonfinancial incentives are needed in addition to the financial incentives. Congress recognized this inherent need by exempting clinicians in APMs from the quality reporting approaches for clinicians in fee for service (i.e. MIPS). Recently, we have seen a retreat from this intent with several policies requiring clinicians in APMs to align to MIPS (e.g., eCQM reporting, PI reporting). We believe this alignment approaches is flawed. APM approaches that support population health should be the gold standard, with MIPS aligning to those policies to support the movement to value. Additionally, other policies within the program (e.g. beneficiary notification requirements) introduce an unnecessary burden and should be revised.
Accelerate innovation to retain longstanding participants. Long-term ACO participants have achieved significant savings to the program and successfully developed care redesign approaches that are adopted by newer participants. We must recognize that these long-term participants need additional avenues to continue to innovate within the program. The Innovation Center has tested several approaches that should be incorporated into MSSP, including population based prospective payments, higher risk tracks and a broader set of waivers. CMS should prioritize adopting these approaches in the permanent program.

Across each of these areas, we must recognize that adoption of accountable care remains voluntary. Clinicians and providers continually grapple with choosing a pathway of volume-based revenue opportunities in fee-for service and the opportunity to innovate care that accountable care offers. All MSSP policies must recognize that broader competitive landscape that; as fee-for-service remains a strong option, MSSP must have stronger incentives. Our detailed recommendations offer opportunities to ensure that MSSP retains stronger incentives.

NAACOS Members: Please provide any comments on the draft letter to [email protected]. Additionally, we are requesting additional feedback from members in a few areas noted in red throughout the document.

Correcting the ACO Ratchet Effect

NAACOS has long advocated for fair and accurate financial benchmarks that create achievable spending targets for ACOs to generate shared savings. CMS must balance creating program policies that generate savings to Medicare while retaining participants in a voluntary model. NAACOS implores CMS to consider changes to mitigate benchmark ratchets that occur when rebasing.

We believe the ratchet effect threatens future participation in ACOs, particularly for long-term ACO participants. For example, one ACO who began in MSSP in 2012 is approaching its fifth agreement and yet another ratcheting of its historic benchmark. The ACO’s spending is now 25 percent below that of its region, which should be hailed as a policy success. Instead, the ACOs savings will become smaller (since savings’ opportunities will shrink with its benchmark) and the cost of running its care management programs will exceed shared savings. When this happens, their local health system, which continues to operate in FFS only, will have more revenue to hire away the ACO’s clinicians. ACO participation is voluntary, and CMS must recognize the broader financial realities when developing benchmark policies.

It will be critical for CMS to consider variations in regional spending when addressing the ratchet. Regional variation in spending is inherent in fee-for-service, and as such, needs to be considered when setting and addressing ACO benchmarks, including addressing the ratchet and setting an administrative growth rate in benchmarks. This was borne out earlier this year in ACO REACH and changes to the Medicare hospital wage index. Because of changes to the wage index, ACOs in some regions would see big increases in hospital spending through no fault of their own. As CMS looks to solve the ratchet effect, the size of the ratchet depends on how efficient the region is, and ACOs in more efficient regions need a higher prior savings adjustment to offset the lack of help provided by the regional adjustment. Relatedly, NAACOS continues to urge CMS to fix the “rural glitch,” where CMS counts an ACO’s own beneficiaries in the regional benchmarking calculations, effectively penalizing ACOs for lowering the cost of their assigned populations.

Increase the Amount of the Prior Savings Adjustment
A prior savings adjustment is needed to help curtail the ratchet effect. For new agreement periods starting next year, CMS will calculate ACO savings generated in the prior three years and add some of those savings back into ACO benchmarks. However, that add back is capped at 50 percent of savings generated, which cannot exceed 5 percent of national FFS spending, the same cap applied to an ACO’s positive regional adjustment. The add back is also limited to the three years prior to the start of the new agreement period. NAACOS continues to feel this is not enough to help ACOs who have generated billions in savings for Medicare. Below are changes we’d like to see to the prior savings adjustment.

Use ACOs’ maximum shared savings rate from their prior agreement period. For example, this would increase the prior savings adjustment to 75 percent for Enhanced ACOs.
Allow the prior savings adjustment to be more than 5 percent of national FFS spending. The cap on the adjustment effectively limits successful ACOs’ or ACOs who serve high-costs population. For these ACOs, a cap of 5 percent may represent more than a 50 percent scaling factor of the prior contract’s savings.
Risk adjust any caps (i.e. currently 5 percent national FFS spending) to make it a more accurate reflection of the complexity of the patient population.
Consider examining more than three years of savings for ACOs with a great history of participation. Some ACOs have been in MSSP for more than a decade and have millions in savings not captured by a shorter, three-year look back period.
Employ a scaling factor to the prior savings adjustment to increase the adjustment based on ACOs’ spending compared to its region. For example, an ACO whose spending is 10 percent below its region could be capped at 7.5 percent. An ACO whose spending is 15 percent below its region could be capped at 10 percent. An ACO whose spending is 25 percent below its region could be capped at 15 percent. Currently, CMS policy of ratcheting every ACO back to a 5 percent of national FFS spending prevents any long-term investments that would require greater than a 5 percent savings rate to generate a return.
Don’t penalize ACOs in their prior savings adjustment if their spending is higher than that of their region. This would penalize providers who serve high-cost patients.
Lastly, it would be helpful if CMS would clarify that REACH ACOs would be eligible for a prior savings adjustment should they enter or reenter into MSSP. The current regulation is unclear but allowing REACH ACOs to be eligible would meet the overall intent of the policy.

NAACOS Member Additional Feedback: We would like your examples of the impact of the ratchet on your ACO.

Improve the Accountable Care Prospective Trend
Also starting in new agreement periods starting next year, CMS will incorporate a new Accountable Care Prospective Trend (ACPT). The ACPT will be a third of the update to ACO benchmarks, along with the existing two-way, national-regional blend. NAACOS had previously asked CMS to pause the ACPT’s implementation and supports it replacing the national portion of the current national-regional blend, which CMS recently sought comment on.

As CMS considers its next steps on administrative benchmarks, it must prioritize one factor: Base the administrative trend on an ACO’s region. A single, national trend can never be reflective of everyone’s individual experience across the nation. This occurs with the ACPT when an ACO’s regional trend is lower than national spending increases. The ACO would be negatively impacted in this instance. ACOs should not be punished if they operate in regions with spending growth below that of national inflation.

There are ways to improve the ACPT:

Use the ACPT as the national component of the current two-way trend adjustment, rather than observed national FFS spending. This creates a benchmark that is based less on national spending and more on regional spending, which is a policy NAACOS has long advocated for.
Remove ACO-assigned beneficiaries from the regional comparison group, negating the effect of ACOs’ savings on the regional trend. This would still allow CMS to move toward its goal of an administratively set benchmark while minimizing the unintended consequences of harming nearly a third of ACOs.

CMS should create additional guardrails to protect ACOs who would see lower benchmarks because of the ACPT. These include:

Setting ACOs’ historic benchmark at the higher of the proposed three-way trend adjustment or the current two-way trend adjustment.
Basing the ACPT on regional spending, rather than national. Because there is significant variation in regional spending growth, the use of a national trend will benefit ACOs in regions with slower spending growth and reduce benchmarks for ACOs in regions with higher spending growth.
Using a three-year projection of the ACPT, which is the current projection used in the USPCC. It would be difficult to project five years out, and reserving the right to make mid-agreement period adjustments simply introduces uncertainty.

CMS should explore additional questions when pondering further incorporation of administrative benchmarks.

1) How much of a “wedge” does CMS find it acceptable to create? The wedge is the slice of spending growth between that of ACOs and that of Medicare spending. Under current policy, it is effectively 5 percent, the size of the cap on the regional and prior savings adjustments. That is too small to drive innovation, particularly in a world where provider organizations can achieve much greater in Medicare Advantage.

2) How big of a skew in the trend would trigger the need for a guardrail? NAACOS calls for stronger guardrail policies above, and CMS includes some under the current ACPT policy. CMS needs to consider how big of a difference between expected trend and actual trend would trigger additional policies to ensure ACOs are not unfairly penalized.

It’s important to remember that any move to administrative benchmarks won’t solve this problem of benchmarks starting off at unachievably low levels because of ratcheting due to rebasing. This ratchet does not just cap savings, it caps investments in beneficiaries, and it caps how much an ACO can truly transition away from FFS and towards value.

Quality Reporting and Assessments

eCQMs, MIPS CQMs and Medicare CQMs
ACOs have a desire to see more digital measurement approaches incorporated into quality reporting. An efficient, technology-enabled future where data can be shared bi-directionally to better inform patient care is the future state many in the health care industry want to achieve. Digital measurement should allow for seamless quality reporting that reduces burden and provides real time performance data that can be used to improve patient care. This should facilitate more efficient exchange and evaluation of quality data. While this efficient, technology-enabled quality reporting is a future state ACOs want to strive toward, moving to a program-wide electronic clinical quality measure (eCQM)/ MIPS CQM reporting requirement goes beyond simply digitizing the previous well-established process of Web Interface sample-based reporting. As CMS attempts to move the MSSP closer to this future state of interoperability through the required use of eCQMs, the agency must address the unintended consequences and implications for ACOs, the clinicians in those ACOs and the patients they serve.

We are pleased to see CMS finalize an interim reporting option that begins to address many of the unintended consequences of moving to eCQM reporting for ACOs that NAACOS and ACOs have raised through the Medicare CQM reporting option for ACOs. However, we continue to have concerns regarding CMS’s larger goal to require all ACOs report all-payer eCQMs/MIPS CQMs, while making no changes to these reporting types. CMS notes this is intended to be a temporary, transitional reporting option. This will result in the same challenges being present for ACOs when the reporting option is eliminated because changes have not been made to the eCQM or MIPS CQM reporting options. The MSSP program-wide pay-for-performance implementation of eCQMs/MIPS CQMs should not move forward without proof-of-concept of both technical feasibility and the impact of the shift to all-payer measurement for ACOs. CMS must also consider future digital quality measurement (dQM) goals and how this proposal works to further that goal. ACOs should not have to invest in developing processes now that will need to be replaced in the near future.

We urge CMS to:

Allow the Medicare CQM option to continue until CMS has tested technical capabilities and the impact of the shift to all-payer measurement and dQMs for ACOs through a pilot, or until digital quality measurement and reporting is feasible for all ACOs;
Pilot eCQMs and dQMs for a subset of ACOs to identify key challenges and unintended consequences that need to be resolved before moving forward on a program-wide basis. CMS should provide incentives for ACOs to do this testing, such as providing pay-for-reporting status for quality measures, upfront funding, adjustments to financial benchmarks, or an increased savings rate to help offset the high costs for doing this work;
Create Electronic Health Record (EHR) certification criteria that supports ACOs in what they are required to achieve for electronic clinical quality and digital quality measurement. CEHRT requirements do not standardize the capture and reporting of individual eCQM data elements across vendor systems and not all CEHRT vendors will implement every eCQM required for ACO reporting unless made a requirement for CEHRT;
Allow for alternative data completeness standards for ACOs reporting eCQMs or MIPS CQMs, or allow for exceptions/exclusions that acknowledge the difficulty of aggregating data across ACO participants. Specifically, we urge CMS to clarify that the data completeness standard applies to the percent of ACO participants; and
Identify an alternative pathway to transmit data in a standardized way to enable successful patient matching, such as use of a national patient identifier or revisions to QRDA I formats.

Aligning ACO Measures with the Universal Foundation Measure Set
ACOs support efforts to align quality measures across payers, contracts and payment models. However, CMS must ensure measures that have not been tested are optional as the agency moves forward with efforts to adjust measure sets to align with the new Universal Foundation measures. As CMS considers changes to the MSSP measure set to align with the Universal Foundation, the following issues must be addressed:

CMS must first test measures before making them required and scored measures for ACOs.
CMS should avoid making any mandatory changes during the timeframe they are also asking ACOs to transition to new reporting methods. ACOs are currently devoting large amounts of time and resources to making operational and Information Technology changes to implement the measures currently required for eCQMs, MIPS CQMs and Medicare CQMs. Adding new mandatory measures to this list at the same time ACOs are required to fully transition to these new reporting methods will add significant burden and impede their ability to succeed.
Ensure there is not significant growth in the number of measures ACOs must report. CMS started the MSSP with over 30 quality measures, and over time reduced the measure set to reduce burdens associated with reporting. This should continue to be a focus for CMS.

Incorporating MIPS Value Pathways (MVPs) in MSSP
NAACOS opposes the mandatory use of MVPs in ACOs. Many of the specialty measures used in the MIPS program are not oriented toward value-based care and therefore would have very little utility and add significant burden, complexity and confusion. Instead, CMS should allow ACOs to continue to identify the best ways to engage specialists in value arrangements. Many ACOs are currently working with specialists to address access and care coordination, which are critical to value-based care work. This is another example of the misalignment that takes place when the MSSP or other value models are combined with a fee-for-service focused program such as MIPS. We continue to advocate for CMS to remove ACOs from MIPS, which adds burden and without any benefits to the value work they are already engaged in through their participation in value-based care models.

Promoting Interoperability and CEHRT Requirements for ACOs
NAACOS is disappointed CMS is moving forward with a requirement to align Certified EHR Technology (CEHRT) requirements for MSSP ACOs with MIPS. NAACOS strongly opposes this policy which will add significant burden to ACOs and further disincentivize participation in APMs and Advanced APMs and we urge CMS to reconsider this policy. By requiring all ACOs’ eligible clinicians to report Promoting Interoperability, regardless of track or qualifying APM participant (QP) status, CMS is creating yet another disincentive for ACOs to participate in an Advanced APM and obtain QP status at a time when the financial incentives in place for this participation are expiring. CMS notes their intention with this policy is to reduce burdens for ACOs, however the result is the opposite. Instead, CMS is now creating a new reporting obligation for ACOs who participate in an Advanced APM and obtain QP status. Lastly, QPs are statutorily excluded from the MIPS program and this policy subjects QPs to MIPS, as Promoting Interoperability is the only reporting obligation ACOs have in the program.

While we appreciate CMS’s one year delay in the requirement’s enforcement, ACOs will still struggle to comply with this change. CMS must ensure ACOs still have the opportunity to bring small practices who are not currently on CEHRT into the ACO to advance value-based care and support CMS’s stated goal of having all patients in an accountable care relationship by 2030. ACOs can provide resources and assistance for transitioning to CEHRT, however this can take time. The current 75 percent attestation approach allowed ACOs to bring these practices into value arrangements, which advances the goals of population health. Should CMS move forward with this policy, they will stifle growth in ACOs and take CMS further from their goal of having all patients in an accountable care relationship by 2030. Many ACOs are now faced with the difficult decision of needing to drop small, independent practices from their participation. CMS must signal a change in this policy prior to the September deadline to add or drop ACO participants to avoid losing participation from this critical group of clinicians in value models.

We also have several implementation questions and concerns for this requirement. We are concerned with CMS’s recommendation that ACOs report PI at the APM Entity level. This is not possible unless the ACO is a single TIN comprised of a single EHR product. CMS also notes that ACOs will be responsible for checking the individual eligibility of clinicians across their ACO at multiple times in the performance year to determine who must report. This is simply not feasible and CMS should instead provide ACOs with a list of clinicians they are expected to report on. Importantly, CMS must also clarify that the small practice exception is applicable to small practices in the ACO either as an automatic exclusion or an exception. CMS must also clarify how clinicians in an ACO are expected to apply for hardship exceptions, and who would receive the notifications regarding approval status for those applications. Finally, CMS must clearly outline the audit expectations and responsibilities, for example, would the ACO be responsible for complying with audit requests, or would this fall on the practice. These questions demonstrate the complexity and burden that is being introduced with the addition of this requirement.

Beneficiary Notifications

NAACOS continues to advocate for more sensible and effective approaches to beneficiary communications in MSSP. In previous feedback to the agency, we detailed concerns with the requirements as currently written and highlight key challenges ACOs face in implementing and complying with these requirements. Through conversations with ACO members and consumer advocacy organizations, we have summarized four overarching issues with the beneficiary notification requirements:

ACOs lack access to information needed to identify the denominator of beneficiaries to which they are required to provide the notice and follow-up.
The timing requirements of the initial notice and follow-up are impractical and make it effectively impossible to be fully in compliance.
Lack of appropriate guidance from CMS and contradictory information provided by ACO coordinators have caused significant confusion among ACOs about how to comply with the requirements.
These requirements have caused confusion and frustration for Medicare beneficiaries, in direct contrast with the intention of the requirements.

Additional detail on each of these four areas can be found on pages 21-23 of NAACOS comments on the 2024 Medicare Physician Fee Schedule Proposed Rule.

NAACOS has also recommended changes to the “Medicare & You” handbook, which CMS provides annually to each Medicare household, to include information on MSSP and the agency’s accountable care goals. NAACOS is a strong supporter of CMS’s goal to have all Medicare beneficiaries in a relationship with a provider accountable for their quality and total cost of care by 2030. Effectively communicating with and educating beneficiaries about accountable care will be essential to achieving this goal. NAACOS will continue to engage with CMS and other stakeholders, including patients and consumer advocates, to improve beneficiary communications as they are critical to expanding the reach of accountable care and to the success of patient engagement activities. We plan to convene a group of ACO leaders and consumer advocates to develop commonsense solutions to these challenges and we look forward to sharing the resulting recommendations with CMS.

Primary Care Hybrid Payment

More flexible payment mechanisms can support care delivery transformation, strengthen primary care, and increase participation in ACO initiatives. Specifically, the National Academies of Sciences, Engineering, and Medicine (NASEM) recommends shifting primary care payment toward hybrid models that include prospective population-based payment in addition to a per-visit payment.

A primary care hybrid payment option in MSSP could also advance CMS’ goal of having all traditional Medicare beneficiaries in a care relationship with accountability for quality and total cost of care by 2030. There is broad multistakeholder support for a hybrid payment option within MSSP, including primary care clinicians, ACOs, consumer organizations, health plans and others. NAACOS and others have called on CMS to implement an option to provide prospective payment for primary care within MSSP and outlined payment approaches that accommodate the differing needs and capabilities of various primary care practice types.

NAACOS appreciates CMS’ collaboration with our members and other stakeholders on the development of a hybrid payment option for MSSP and we were pleased to see CMS reference such an option in a blog post and in the proposed 2024 Medicare Physician Fee Schedule rule. In order to make this option feasible and attractive for as many ACOs as possible, CMS should:

Allow select TINs in an ACO to participate, rather than requiring participation of all TINs in the ACO. This ensures that 1) the option is fully voluntary for both the ACOs and all participating practices and 2) one practice in an ACO that does not wish to participate would not have veto power over the participation of other practices in the ACO.
Provide sufficient data and technical assistance to the ACOs and the primary care practices participating in this option to support management and administration of population-based payments.
Ensure the amount of the hybrid payment is greater than historical FFS payments and sufficient to fund advanced primary care and population health initiatives (e.g., chronic disease management, behavioral health integration, addressing social needs, etc.).
Establish appropriate guardrails that balance the need for transparency and accountability while minimizing administrative burden.

We look forward to our continued collaboration with CMS on this proposal and encourage the agency to work expeditiously to implement primary care hybrid payment in MSSP as soon as feasible.

NAACOS Members Additional Feedback:

What technical support would your ACO need to operationalize primary care capitation in MSSP?
What specific data could CMS provide to enable your ACO to administer hybrid payment to primary care practices?
For REACH ACOS: What data are provided in REACH that are most helpful in supporting primary care capitation? What information is not provided in REACH that you think could improve your use of PCC?

Offer “Enhanced Plus” Opportunity for Higher Risk and Reward

NAACOS for some time has advocated for CMS to offer a higher-risk track in MSSP than the current Enhanced track, which we’ve called “Enhanced Plus.” This would serve the dual purpose of encouraging ACOs to take on higher levels of risk, which would in turn produce higher savings, drive innovation, and improve patient care overall. It would also provide REACH ACOs with an offramp from the model that is set to expire at the end of 2026 and better leverage MSSP as an innovation platform, which is a CMS goal. We were pleased to see CMS seek comment on the concept in the 2024 Medicare Physician Fee Schedule proposed rule.

Our concept for “Enhanced Plus” would offer a bridge between Enhanced and what today is ACO REACH, all while providing more flexibility and innovation that allow providers to deliver optimal patient care in ways that best suit them and their populations. We offer a summary of our thinking below.

Risk Sharing
CMS should offer a choice between a full-risk option with a manageable discount or a shared savings rate of 85 percent or 90 percent. CMS needs to acknowledge that the financial incentives under Enhanced are attractive with its 75 percent shared savings rate and a 40 percent shared loss rate. In a full-risk model with either a 2 percent or 3 percent discount, ACOs would have to generate savings of 8 percent or 12 percent, respectively, to earn more than in Enhanced.

There is precedence as ACO REACH offers two levels of risk and Next Gen offered options for percent shared savings (80 or 100), variable discounts, and caps on savings and loss rates between 5 percent and 15 percent. These options provide a tradeoff between how much ACOs could pay back to the Medicare trust fund or reinvest in incentives or patient care.

Another option is to set the discount to max out at half of the average shared savings earned for the program. For example, if ACOs in Enhanced Plus averaged 5 percent savings for a particular year, the discount would top out at 2.5 percent. This would avoid current challenges in ACO REACH where the average net savings for Standard ACOs was less than 1 percent in 2021 after the discount. We understand that CMS must balance savings to Medicare with incentives to attract providers in the model.

Non-Financial Incentives
It will be critical for CMS to also consider non-financial incentives to entice participation in a full-risk model given the relative attractiveness of the current Enhanced model. Few ACOs can generate the levels of savings needed to make a full-risk model with a discount more attractive. The answer lies in waivers and other non-financial incentives, which we spell out below.

Population-based payments—As we note above, we would like MSSP to include prospective population-based payments for primary care. Enhanced Plus should allow options for population-based payments. This would allow ACOs to enter negotiated payment arrangements with specialists and preferred providers, which is a concept not present today in MSSP.
NPI-level participation – Innovation Center models have been very attractive for ACOs comprised of large health system and multispecialty practices because of their ability to be more selective on participants than the full-TIN model participation of MSSP. An Enhanced Plus model should allow TIN/NPI participation to allow ACOS better select its participants.
More waivers and flexibilities – Waivers available today in MSSP have become increasingly stale. In contrast, Innovation Center models offer much better ways to meet patient needs. Enhanced Plus should offer more advanced waivers, including the post discharge home visit waiver, care management home visit waiver, tailored Part B cost sharing support, and others being tested under ACO REACH. ACOs should have maximum flexibility to determine how to implement the benefit.
Better access to data – Managing populations requires access to data to understand your patients, their health, their needs and where they’re seeking care. Enhanced Plus should provide access to better beneficiary-level data. This includes data dashboards that existed under Next Gen, which were well used and very appropriate.
Paper-based voluntary alignment – ACO REACH’s paper-based voluntary alignment has been well utilized and helps ACOs better engage patients. We hope it could be deployed to MSSP to better engage patients. Additionally, CMS should consider speeding up the timeline for aligning beneficiaries through voluntary alignment; perhaps considering a monthly update as currently it can take several months between when a beneficiary voluntarily aligns before they show up on an ACO’s patient roster.

NAACOS Member Additional Feedback: Additional enhancements to include in a higher risk track?

CONCLUSION

Thank you for the opportunity to provide feedback on ways to improve MSSP and increase ACO participation. NAACOS and its members are committed to providing the highest quality care for patients while advancing population health goals for the communities they serve. We look forward to our continued engagement on this model. If you have any questions, please contact Aisha Pittman, senior vice president, government affairs at [email protected].

Sincerely,

Clif Gaus, Sc.D.
President and CEO
NAACOS

NAACOS

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