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CHA has submitted the attached comment letter to the Centers for Medicare & Medicaid Services (CMS) on its proposed rule that would make changes to the Medicare Shared Savings Program. CHA thanks members for their feedback, which helped inform these comments.
In the letter, CHA outlines a number of principles that members believe are critically important in new alternative payment model designs. CHA appreciates CMS’ continued stakeholder engagement on its new direction for the Center for Medicare & Medicaid Innovation and the development of new alternative payment models, and urges CMS to reconsider a number of provisions.
CHA supports CMS’ proposal to allow inexperienced re-entering and renewing accountable care organizations (ACOs) an additional year of upside-only risk, but requests that new, inexperienced ACOs be allowed three years — rather than two — in upside-only risk.
CHA does not support the proposed differentiation between high- and low-revenue ACOs. Instead, CHA encourages CMS to consider the program’s original intent, and significantly revise the methodology used to reward improved quality and reduced costs.
Additionally, CHA does not support the proposed benchmarking methodology that determines ACO savings or losses, as it would continue to disadvantage states — like California — that have continued to increase health care system efficiency under a largely managed care market.
