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The AHA appreciates certain steps the Centers for Medicare & Medicaid Services is taking to improve the stability and flexibility of the Medicare Shared Savings Program; however, the association is concerned that “as a whole, the proposals in the rule would likely result in significant decrease in MSSP participation,” AHA told the agency today. 

“While such an outcome may very well be CMS’s expectation, it unfortunately disregards many of the lessons we have learned from the current program,” AHA wrote in response to CMS’s recent proposed rule that would make changes to the MSSP and provisions relating to Medicare payments to providers of services and suppliers participating in accountable care organizations under the MSSP.

Specifically, AHA urges CMS not to finalize the proposed differentiation of participation options for high- and low-revenue ACOs. Instead, CMS should improve its program methodology to accurately reward performance for improving quality and reducing costs, and offer resources and assistance to all ACOs, AHA said. 

The agency also should allow ACOs that are new to the program three years in upside-only risk, rather than two, as proposed, AHA said. In addition, the agency should maintain the ability for ACOs to elect to move into downside risk prior to completing three performance years, if they so wish. 

AHA also offered recommendations related to expansion of access to waivers; proposed changes to benchmarking methodology; and election of minimum savings rate/minimum loss rate.