The Medicare Physician Fee Schedule, always a major vehicle for ACO policy changes, was proposed by CMS earlier this summer. The rule included important changes for ACOs, including an additional two years to phase in the new quality measurement system. CMS is also proposing extended and expanded telehealth authorities, including new mental telehealth and RHC/FQHC telehealth flexibilities, reduced escrow for risk-bearing ACOs, and streamlined application and beneficiary notification processes. Caravan submitted our comments on the rule earlier this week.
Two-year delay/phase-in for quality overhaul: Caravan supports many of the proposals in the rule, but we are still concerned about whether ACOs will have enough time and guidance to make the quality system work. Our ACOs have been working hard on the quality measurement transition, including upgrading technical systems and training staff. As of now, it’s not clear that ACOs have the necessary agency guidance to make the transition successfully.
Benchmarking: The rule includes extensive discussion about ACO benchmarking. CMS has taken a careful and thorough approach to several benchmarking complexities, such as the rural glitch. The rural glitch arises when an ACO has a disproportionate share of a region’s market. In this situation, the ACO is mostly measured against itself when the regional factor is incorporated into the benchmark. This especially affects rural areas where the ACO may include a larger proportion of FFS beneficiaries than more populated areas. Since ACOs are measured against the benchmark to determine shared savings, the results can be fundamentally unfair. Caravan strongly supports CMS fixing the rural glitch by removing an over-represented ACO’s attributed beneficiaries from the regional component of the benchmark.
Future of rural value-based payment: Rural ACOs have been proven to save money for Medicare and CMS should use all available tools to get rural providers in value-based payment. Rural providers were anticipating the launch of the ACO Transformation track of the Community Health Access and Rural Transformation (CHART) model in January 2022 and were disappointed when the model launch was delayed until 2023. We urge CMS to commit to a 2023 start and issue program guidance as soon as possible.
Health equity: The proposed rule included a request for information about Closing the Health Equity Gap in CMS Clinician Quality Programs. As CMS points out, comprehensive data is the key for addressing the extensively documented and persistent health equity issues. Caravan is proud to be part of a group of health organizations urging HHS Secretary Becerra to advance health equity and value through innovative alternative payment models. The letter lays out steps for HHS to leverage the success of value-based payment in achieving the agency’s vision of improving disparities in patient outcomes. Read the coalition letter here.