The Centers for Medicare & Medicaid Services (CMS) has proposed several changes to the Medicare Shared Savings Program (Shared Savings Program) as
The goal of these proposed changes is to advance CMS’ value-based care strategy and address concerns raised by accountable care organizations (ACOs) and other stakeholders. Here are the key proposals:
- Digital Measurement of Quality: CMS proposes establishing a new Medicare Clinical Quality Measure (CQM) collection type for ACOs under the Alternative Payment Model (APM) Performance Pathway (APP) to move ACOs towards digital measurement of quality.
- Refinements to Financial Benchmarking Methodology: CMS suggests refinements to the financial benchmarking methodology for ACOs, including applying a symmetrical cap to risk score growth in an ACO’s regional service area, using the same risk adjustment methodology for both benchmark and performance years, and mitigating the impact of negative regional adjustment on the benchmark to encourage participation by ACOs caring for medically complex, high-cost beneficiaries.
- Beneficiary Assignment Modifications: CMS proposes adding a third step to the beneficiary assignment methodology to recognize the role of nurse practitioners, physician assistants, and clinical nurse specialists in delivering primary care services. This step would provide greater recognition of their contribution and update the definition of primary care services used for beneficiary assignment.
- Updates to Advance Investment Payments (AIP): CMS suggests refinements to policies for advance investment payments, including allowing ACOs to progress to performance-based risk, modifying recoupment policies, requiring reporting of spend plan updates and actual spend information, and allowing ACOs to seek reconsideration review of payment calculations.
- Alignment with MIPS Requirements: CMS proposes aligning the certified electronic health record technology (CEHRT) requirements for Shared Savings Program ACOs with the MIPS program. This would involve removing the Shared Savings Program CEHRT threshold requirements and requiring ACO participants to report MIPS Promoting Interoperability (PI) measures and earn a MIPS performance category score.
- Quality Performance Standard and Reporting: CMS proposes establishing Medicare CQMs for ACOs participating in the Shared Savings Program to transition them to reporting digitally on their Medicare patients. Data completeness criteria and benchmarks for scoring ACOs on Medicare CQMs would be aligned with MIPS requirements. CMS also plans to expand the health equity adjustment to Medicare CQMs to support ACOs that deliver high-quality care to underserved populations.
- Risk Adjustment and Benchmarking: CMS proposes capping regional service area risk score growth to ensure symmetry with the cap on ACO risk score growth. They also propose using the same CMS-HCC risk adjustment model for benchmarking in the Shared Savings Program as used in the performance year to address inconsistencies between benchmark and performance year risk adjustment.
CMS is also seeking public comments on potential future developments in Shared Savings Program policies, including the incorporation of a higher-risk track, modifications to the prior savings adjustment and regional adjustment, and approaches to promote ACO and community-based organization (CBO) collaboration.
The proposed rule is open for a 60-day public comment period, which closes on September 11, 2023.
Sourced from CMS.gov