Statement on MSSP proposed rule Last Updated: March 25, 2015
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By Blair Childs, senior vice president of Public Affairs, Premier, Inc.

Members of the Premier alliance applaud the Centers for Medicare & Medicaid Services (CMS) for proposing vital changes to the regulations governing the Medicare Shared Savings Program (MSSP). Based on the experiences of providers participating in Premier’s PACT Population Health Collaborative, one of the largest accountable care organization (ACO) performance improvement collaboratives in the country, we believe some of these changes remove serious hurdles that are inhibiting provider success and participation.

Specifically, we support CMS’s proposals to honor beneficiary choice by allowing them to opt into the program through an attestation process. We also applaud CMS’s proposal to waive certain fee-for-service payment rules that now inhibit clinicians from using their best medical judgment as to the best time and place for care. We are also pleased that CMS appears willing to revisit the instability of the financial benchmarks and the inequity of the risk adjustment methodologies.

We believe, however, that CMS needs to do much more to improve the one-sided risk model. In fact, it proposes to reduce the already inadequate shared savings payments for ACOs extending their contract under Track 1 from 50 percent to 40 percent in year 4, stepping payment down an additional 10 percent each year to reach 20 percent in year 6. This will impede participation and inadequately recognizes the financial and transformational contributions made by participating providers.

We believe the MSSP provides an important model to transition from Medicare’s fee-for-service to one that incents value and population health. We look forward to working with the agency to further refine the program rules.

By Blair Childs, senior vice president of Public Affairs, Premier, Inc.


For details on the proposed rule, see Premier’s summary.