The 2021 Medicare Physician Fee Schedule, published in early August, proposed major changes for ACOs and other value-based payment models. Highlights of this year’s rule include extension of some telehealth flexibilities, a dramatic reduction in the number of ACO quality measures and changes to reporting methods, and a new framework for assessing quality for alternative payment models that report through MIPS. Though the rule came out later than usual, CMS says it will be finalized and in effect for January 2021.  


Caravan Health just submitted its comments to CMS - see our letter here
 

The proposed rule has some good news for our providers, including the extension of some telehealth and virtual care services. While there are some telehealth and virtual care extensions that would take an act of Congress, CMS has taken a thoughtful approach to making these services more widely available to the extent of their authority. Many of our rural clients and patients have come to rely on virtual care to manage chronic disease and maintain preventive care during the pandemic We have heard from many clients that having an established population health framework has been invaluable to pivoting to virtual care during the public health emergency.  

CMS is also recognizing the value of office-based evaluation and management (E/M) services and increasing reimbursement. These office visits are time-intensive, especially for Medicare patients with serious chronic medical conditions and we applaud CMS for compensating these providers appropriately.  

Not all the changes proposed in this rule are great news for ACOs. We have concerns with several proposed changes to quality reporting and measurement. Building and running an ACO is hard work, and ACO providers need to be able to distinguish themselves to be rewarded for the effort they put in. The proposed dramatic reduction in the number of ACO quality measures would be a move in the wrong direction. Not only do ACOs lose the ability to stand out due to quality, but many of the measures that would be dropped are those that give a full picture of preventive care performance, such as tobacco use, flu vaccinations, fall risk, and cancer screenings. ACOs need every tool to make the case to patients, providers, and payers that they are excelling at preventive care.  

It may make sense to eventually reduce the burden on providers from reporting quality measures, but this change raises the risk of disadvantaging ACOs compared to MIPS-eligible clinicians not participating in alternative payment models. We have similar concerns about removing the option for web interface reporting. Making changes to the methods for submitting data during a public health emergency puts undue burden on providers at a time they need stability.  

Caravan has been pleased to see the many ways that CMS is supporting ACOs as they make their way through this public health emergency. ACOs have transformed care and returned savings to Medicare. While we are under so much stress from the public health emergency, ACOs should be supported and not have to adapt to major changes as they weather the coronavirus crisis

See our full letter to CMS here.

 


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