Citing the ongoing COVID-19 Public Health Emergency, a large group of leading healthcare organizations on Sep. 23 urged Seema Verma, Administrator of the federal Centers for Medicare & Medicaid Services (CMS) to not move forward with sweeping changes to how accountable care organizations (ACOs) and other alternative payment models (APMs) are assessed on quality in the Medicare Shared Savings Program (MSSP) and Merit-Based Incentive Payment System (MIPS).
The coalition of groups, composed of the American College of Physicians, American Medical Association, America’s Essential Hospitals, America’s Physician Groups, AMGA, Association of American Medical Colleges, Federation of American Hospitals, Medical Group Management Association, National Association of ACOs, and Premier Inc., wrote the letter to Administrator Verma, asked that Verma not implement changes proposed to the 2021 Medicare Physician Fee Schedule that would alter the way ACOs report and are measured on quality. The full text of the letter can be found here.
Addressing Verma, the signatory organizations wrote that “The undersigned organizations write to provide comments on the proposed quality revisions for Accountable Care Organizations (ACOs) included in the proposed 2021 Medicare Physician Fee Schedule rule. CMS proposes sweeping changes to how ACO quality is assessed, how quality data is reported and how ACOs are evaluated on quality for both the Medicare Shared Savings Program (MSSP) and Merit-Based Incentive Payment System (MIPS). We appreciate that the Centers for Medicare and Medicaid Services (CMS) has considered how to reduce the required number of measures, provide flexibility in how measures are submitted and mitigate potential reductions in 2020 performance by using the higher of 2019 or 2020 scores,” the groups wrote. “However, the timing of these changes is very concerning as ACOs continue to deal with the uncertainty that the COVID-19 Public Health Emergency (PHE) is bringing to the health care industry. Additionally, the expected delayed release of the final rule further reduces the amount of time ACOs and other Alternative Payment Models (APMs) will have to implement such changes.”
The groups wrote that “Quality improvement is a cornerstone of the ACO model. In addition to reducing spending, ACOs must meet certain quality performance standards to be eligible to receive shared savings payments. ACOs continue to improve quality year over year, which improves patient care and helps to control costs,” they wrote. “It is critical that CMS policies to evaluate ACO quality are fair, appropriate and accurately reflect the work ACOs engage in to improve patient care. CMS’s proposals to change the way ACO quality is assessed, reported and scored for purposes of shared savings calculations are significant and more feedback should be collected before moving forward with such drastic changes.”
Among other specifics, the groups emphasized:
Ø That CMS’s abruptly ending the use of the web interface reporting mechanism would be “ill-timed and unfair.”
Ø The groups emphasized that “The proposed rule would also remove the pay-for-reporting year currently provided to ACOs beginning an initial MSSP contract as well as individual measures that are newly introduced to the measure set. It also would remove the ability of CMS to provide pay-for-reporting when measures undergo significant changes, such as guideline changes. We oppose CMS’s proposal to remove pay-for-reporting. Providing the pay-for-reporting year is critical to an ACO’s success,” they stated.
Ø Referencing the Alternative Payment Model Performance Pathway (APP), the groups stated that “CMS also proposes significant changes to the quality measure set ACOs must report under the new APP. While a reduction in measures is generally supported and may reduce reporting burdens,” the stated, “we do not feel the current proposed APP measure set is appropriate and we instead urge CMS to take more time to gather more stakeholder input, such as through a Request for Information (RFI) or open stakeholder forum and seek feedback from the Measure Applications Partnership (MAP).”
And, the groups wrote at the end of the letter, “In conclusion, the ACO quality changes proposed are significant and come at a time when ACOs are continuing to deal with challenges and uncertainty caused by the COVID-19 pandemic. Just as CMS has proposed to delay moving forward with the MIPS Value Pathways (MVP) approach due to concerns with COVID-19, CMS should also postpone such a drastic and significant change to the way ACO quality is measured, assessed, reported and scored for purposes of both the MSSP and MIPS programs. The undersigned organizations ask CMS to not finalize these proposals at this time and continue to collect stakeholder feedback on this very important issue which affects APMs and the patients they serve. We would be happy to continue to provide additional input on the future of ACO quality measurement.”
