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Premier Comments on the Medicare Shared Savings Program Proposed Rule

Premier submitted comments on the Centers for Medicare & Medicaid Services (CMS) Medicare Shared Savings Program (MSSP) Pathways to Success proposed rule, recommending changes to ensure that ACOs continue to generate savings for the Medicare program and move healthcare providers toward risk and value-based care models.

Highlights of Premier's comments include:

  • Sufficient time in an upside-only model prior to moving to downside risk. Premier recommends at least three years in an upside-only model for new ACOs entering the MSSP. Beyond the MSSP program, Premier encourages CMS to provide a long-term plan for the transition to value-based and risk-based models.
  • Ensure a business case for taking on risk. Premier urges CMS to ensure that ACOs and new payment models provide strong incentives for taking on risk by:
    • Increasing the ACO shared savings rate from the proposed 25 percent to 50 percent; and
    • Providing additional flexibility in the MSSP for ACOs taking on risk similar to those provided in the Next Generation ACO model and Medicare Advantage.
  • Equal footing to all model participants. Premier strongly discourages the use of policies that advantage one provider group over others. Premier recommends a level competitive playing field and elimination of a distinction between high- and low-revenue ACOs.
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