In pursuit of the no longer optional ‘triple aim‘ and as once suggested by industry innovator Richard Merkin, MD the founder and CEO of Heritage Provider Network, the ‘gold’ in the ACA may be the programs and outreach of the CMMI. But we’re not obsessed with acronym’s in healthcare, right? So for clarity, the ‘ACA’ is the Patient Protection and Affordable Care Act, while the ‘CMMI’ is the Center for Medicare and Medicaid Innovation in the ‘CMS’ – the ‘Centers for Medicare and Medicaid‘.
While health policy and politics are energetically if not occasionally often toxically entwined, the release of NPRM (the notice of proposed rule making) is the current reflection of a feedback loop inherent in our public/private system of ‘partnership governance’. Since we’re coming up on three years in the implementation of the ACA including its principal dog in the hunt of a sustainable healthcare economy (ACOs and their derivative entities) the delivery of these insights have been eagerly anticipated.
For context, the initial reviews of the ACO NPRM (see: ‘The ACO Proposed Rule: A [Skeptical] View From ‘The Street’‘, and ‘Proposed vs. Final ACO Rule’) logged upwards of 1,300+ comments many of which telegraphed the concerns now recognized in the proposed rule ‘Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations‘. The summary notes the intent of the filed NPRM as follows:
This proposed rule addresses changes to the Medicare Shared Savings Program (Shared Savings Program), including provisions relating to the payment of Accountable Care Organizations (ACOs) participating in the Shared Savings Program. Under the Shared Savings Program, providers of services and suppliers that participate in an ACO continue to receive traditional Medicare fee-for-service (FFS) payments under Parts A and B, but the ACO may be eligible to receive a shared savings payment if it meets specified quality and savings requirements.
Since issued, many have chimed in including analyses from Mark McCllelan, MD et al at Brookings (see summary below), the ACO management company founded by former National Coordinator for HealthIT Farzad Mostashari, MD Aledade, The National Law Review, HealthLeaders via ‘Proposed MSSP Changes Don’t Go Far Enough, Providers Say‘ and Rob Lazerow at The Advisory Board.
Risk Assumption, Attribution and Rebasing Savings Baselines
The good news is CMS took provider feedback to heart and addressed the issues above in a meaningful way. The retrospective attribution issue was perhaps the ACO ‘achilles heel’, while a three (3) year contract year extension to upside only participation (Track One) formula recognizes the immature state of many of the ACOs in the MSSP, and the need for additional runway to implement a value based healthcare delivery culture. Finally, the remaining Pioneer class were rather vocal about the dis-incentive of a progressively lowered baseline from which savings (or losses) are calculated.
Comment
We’re clearly in an innovation inspired learning mode thanks to the principle mission of CMMI which is to test:
innovative payment and service delivery models to reduce program expenditures …while preserving or enhancing the quality of care” for those individuals who receive Medicare, Medicaid, or Children’s Health Insurance Program (CHIP) benefits.
So amidst this toxic health policy and ‘politics of what’s possible’ health reform environment we find ourselves with some cause for optimism as many of the key drivers of ACA begin to take hold in a very difficult to restrain volume driven healthcare ecosystem.
The jury is and will remain out until the ACA is fully implemented and the accountable care industry writ large (including ACOs, PCMHs and derivative plays both commercial and public market) post the results of their efforts to improve user experience (outcomes), quality and lower per capita healthcare costs.
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