The AAMC March 28 submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) regarding a proposed rule that would update the methodology used to calculate benchmarks for accountable care organizations (ACOs) that continue their participation in the ACO shared savings program after the initial three-year agreement period.
The proposed changes are focused on incorporating regional expenditures in the methodology for establishing the benchmark so that an ACO’s performance is measured against providers in the same market rather than evaluating an ACO based against its own past performance.
In the letter, the AAMC emphasizes that sustained and increased participation in the Medicare ACO shared savings program will depend on financial opportunities being adequate to support investments needed to improve quality and coordinate care. To keep the program sustainable in the long-term, the AAMC recommends that CMS phase in a blend of historical and regional costs in the reset benchmarks and allow maximum flexibility and choices to ACOs regarding application of the new methodology. This would include allowing some ACOs to begin new agreements with rebased regional benchmarks earlier, and allowing a more gradual phase-in period for others.
The AAMC also urges CMS to change the ACO risk score methodology to include more complete and updated risk adjustments that better reflect the clinical complexity and patient characteristics of the ACO’s population, such as socioeconomic status. To ensure continued involvement of academic medical centers in ACOs, the AAMC also expresses support for the exclusion of indirect medical education (IME), disproportionate share hospital (DSH), and uncompensated care payments from an ACO’s benchmark and performance year calculations.