Allison Brennan Outlines the Greatest Challenges of the Proposed MSSP Changes

The shorter timeline to risk and the reduction of shared savings rates are among the 2 greatest challenges accountable care organizations (ACOs) will face as part of the proposed changes to the Medicare Shared Savings Program (MSSP), said Allison Brennan, MPP, senior vice president of government affairs for the National Association of ACOs.

Transcript

What is the greatest challenge you see as part of the proposed MSSP changes?

I think the greatest challenges that we see are, number 1, the shortening of time that new ACOs have before they have to take on risk. Currently, in the program, new ACOs have 6 years before they’re required to take on risk. Even at the end of 6 years at lot of ACOs find that challenging. This proposal would shorten that time frame down to 2 years, and when we say 2 years it’s also important to note that that really only means that ACOs have only 1 year of performance results. So, essentially, it’s like they’re flying blind to make this big leap. They only have a little bit of data and performance to go on before they move into a risk-based model.

Another really significant challenge that we see in the regulation is the proposal to cut in half the shared savings rates for ACOs. Right now, if ACOs meet the requirements in and they’re eligible to share in savings for the government, they get to keep 50% of that savings. Under the proposal they would only get to keep 25% of the savings. When we’re looking at the investments ACOs are making, upfront, which are not counted in the calculations of risk from CMS, they’re looking at a return on investment that’s now being cut in half. And that’s really just a nonstarter for a lot of ACOs. They just don’t think that’s a viable business model with shared savings rates that low.

A couple other challenges that we see in the regulation, there’s a proposal to introduce the distinction among ACOs kind of along hospital versus physician-led lines and we have some concerns about that proposal and would like to see ACOs being treated, kind of, fairly across the board.

Finally, I would say there is a proposal that would terminate ACOs from their program if their spending is a little than projected, and this is under the guise of program integrity, but we really don’t think this is a program integrity proposal. It’s really just looking at spending being slightly different than the benchmark. So, that’s something we’re very concerned about and will be opposing.