On Wednesday, March 18, ten national healthcare professional association asked leaders in Congress and the Trump administration to act quickly to ensure clinicians focused on value-based care are not inappropriately penalized for the extreme costs of handling the COVID-19 pandemic and can continue to focus their energy on patient care.
In letters to House and Senate leaders, the organizations asked lawmakers to shield participants in accountable care organizations (ACOs) and other value-based payment models from financial penalties because of costs incurred responding to the COVID-19 pandemic. Because ACOs are judged against their spending from previous years, they could spend well more than their pre-determined spending targets in 2020 as they see spikes in hospitalizations and prolonged ICU stays of their ACO patients because of COVID-19.
The groups include the American Academy of Family Physicians, American College of Physicians, American Hospital Association, American Medical Group Association, America’s Essential Hospitals, Association of American Medical Colleges, Federation of American Hospitals, Health Care Transformation Task Force, Medical Group Management Association and National Association of ACOs.
In a letter to Centers for Medicare & Medicaid Services Administrator Seema Verma, NAACOS and others made similar, but more detailed requests:
• Hold clinicians harmless from performance-related penalties for 2020, particularly those in two-sided risk alternative payment models (APMs);
• Make appropriate adjustments to spending targets, performance scores, patient attribution and risk adjustment;
• Consider additional options to support APM participants, including financial support and reinsurance;
• Hold clinicians harmless from quality assessments and reporting obligations for 2020; and
• Delay upcoming program deadlines such as those related to alternative payment model applications and quality reporting.
“Clinicians in value-based arrangements face even higher levels of financial risk as a direct result of COVID-19,” the letter to Verma states. “Any resources they spend to mitigate the spread of COVID-19 will cost them twice, once at the onset and again when spending is evaluated at year end in the context of their value-based performance.”
The timing of the pandemic also creates challenges, as organizations are both in the middle of reporting quality for 2019 as part of ACO programs and the Merit-based Incentive Payment System and have application deadlines for Direct Contracting and the Medicare Shared Savings Program. Allowances should be made for both.
“Some ACOs have spent years investing in the infrastructure and cultural changes needed to succeed in value-based care models. Just as we’re starting to see serious, positive results, a catastrophic pandemic like this could wipe out years’ worth of shared savings and threaten our decade-long movement to accountable care models,” said Clif Gaus, Sc.D., NAACOS president and CEO. “We hope policymakers see the big picture and work to give assurance to ACOs during a once-in-a-lifetime pandemic.”
“In the immediate term, APM participants will be faced with difficult decisions about whether they can continue to afford to provide advanced preventative care, care coordination, and behavioral services, hallmarks of these models,” the letter to Verma states. “Clinicians should be using every tool at their disposal to fight this epidemic; they should not fear having it count against them later. They need assurance from the administration that this will not be the case.”
