AMGA submits comment letter to CMS regarding proposed rule on Medicare Shared Savings Program

On Friday, the American Medical Group Association (AMGA) drafted and submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed rule on refinements to the current framework of the Medicare Shared Savings Program. While many of CMS' proposals reflect that the agency is being responsive to input from healthcare providers and other stakeholders concerning the operational and financial difficulties that threaten the success of the program, AMGA felt that several recommendations could be offered that would help to ensure the viability of the program.

Of particular importance is the need to expand the use of waivers discussed in the proposed rule to all Accountable Care Organizations (ACOs) and not just those that are in risk-bearing arrangements. All ACOs, whether one-sided or two-sided, must make substantial investments to establish a successful program, and this should be recognized, and rewarded, in the regulatory framework. Additional recommendations included making refinements to the beneficiary attribution process and the benchmarking methodology. In addition, AMGA supported many of the proposed changes from CMS including those that would streamline the beneficiary opt-out for sharing claims data and improve the assignment process.

Donald W. Fisher, Ph.D., CAE, President and Chief Executive Officer of AMGA, stated "While we were pleased to see that CMS is continuing in many ways to take the necessary steps to improve the Medicare Shared Savings Program, we still recognize that extending various waivers to all ACOs would be a substantial move toward fully establishing ACOs as a vehicle to improve quality and coordination of care while reducing costs. We remain hopeful that CMS will utilize this opportunity to both reinforce the viability of ACOs as the harbingers of change for the healthcare delivery system and extend any and all advantageous design changes to all Medicare beneficiaries."