Today Evolent Health submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule overhauling the Medicare Shared Savings Program (MSSP). Some in the industry are opposing CMS’s push for all MSSP accountable care organizations (ACOs) to take on downside risk as well as upside risk as too heavy-handed. Evolent, however, believes in health care providers' capabilities to take on more risk for patient outcomes and total cost of care when they have the appropriate support and incentives.
Underscoring the need for strong signals from CMS on the direction of value-based health care, one comment reads: "Ultimately Medicare beneficiaries should have 'no wrong door' to access high-value health care, whether they enter two-sided risk ACOs or similar alternative payment models, or Medicare Advantage plans. Over time, traditional fee-for-service Medicare not tied to value should comprise a much smaller share of the program."
Evolent is recommending that the agency expand the CMS Innovation Center's successful Next Generation ACO program nationwide through either a voluntary "FULL" risk track in MSSP or separately through the Innovation Center’s authority to expand models successful in reducing spending and improving the quality of patient care. CMS's first annual report on the Next Gen ACO program showed significant savings to Medicare — a 1.1 percent reduction in Medicare spending (more than $62 million net of shared savings payments) and improved utilization and quality of care across several domains for the 18 participants in 2016.
Other principles Evolent emphasizes in its comments are the need for greater transparency (including good, timely data) and predictability across CMS ACO programs. Risk adjustment and benchmarking approaches should be fair and communicated well in advance of ACOs’ performance year. Finally, CMS should continue to allow ACOs to choose which beneficiary alignment approaches work best for them — including coupling any voluntary enrollment options with historical or prospective attribution to help smaller ACOs achieve the scale they need to be successful.
About the AuthorMore Content by Ashley Ridlon