The American Hospital Association (AHA) submitted a letter to the Centers for Medicare and Medicaid Services (CMS) on April 17, 2014, recommending modifications to the Medicare Shared Savings Program (MSSP) and the Pioneer ACO program to make both of these programs more attractive to hospitals and health systems.
The AHA letter begins by noting that hospitals and health systems are committed to accountable care. There has been widespread participation in the MSSP and the Pioneer ACO program; even more hospitals and health systems are testing their readiness for accountable care structures in commercial relationships with health plans.
Despite this high level of interest, the AHA expressed concerns about aspects of the design and structure of the Medicare ACO programs that it believes will limit participation in the Pioneer ACO program and the MSSP and will lead to unsustainable programs. The AHA finds support for its position in the initial results on the performance in those ACO Models, which showed nine of 32 Pioneer ACO participants withdrawing after the initial year and which showed that less than 30% of the MSSP participants received any share of savings with respect to the initial performance year.
With respect to the Pioneer ACO model, the AHA recommended the following modifications to encourage broader participation and to lead to operational viability:
The AHA also noted a number of issues with the MSSP that it believes need to be addressed to encourage increased and sustained participation of hospitals and health systems in the MSSP. Generally, the recommendations suggest modifications to provide better information designed to allow more focused care coordination and to permit a greater ability to earn a share of savings and assume less risk. The AHA noted:
With two relatively new ACO programs, it is not surprising that there are a variety of recommendations proposed to help ensure continued hospital interest, increased participation over time and sustainability of the Pioneer ACO program and MSSP. Many have suggested from the start of the ACO programs that their structure created issues for their long-term success as a viable and sustained tool improving accountability. The AHA’s letter highlights a number of key points for consideration.
As CMS reviews the performance results under these programs, we hope CMS will keep an open mind and make adjustments to improve the ACO programs to address identified problems. Adjustments, such as those suggested by the AHA, can be productive in development of sustainable and valuable programs.