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Top Ten Tech Trends 2017: In the Current Policy Moment, Healthcare Leaders Search for Answers

March 20, 2017
by Rajiv Leventhal
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A few months into the Trump administration, plenty of questions remain about the healthcare and healthcare IT policy landscape

On November 8, 2016, Donald Trump was elected to occupy the Oval Office as the 45th president of the United States while Republicans maintained control of both the U.S. House and Senate. For healthcare C-suite leaders, this administration shift brought with it new policy implications to consider in both the short- and long-term.

Now a few months into Trump’s presidency, Healthcare Informatics readers still have a myriad of questions as uncertainty lingers over the future of healthcare policy. As such, our editorial team concluded that the value-based healthcare landscape, within the current policy moment in the U.S., was well worthy of being one of Healthcare Informatics’ Top Tech Trends for this year. Within this trend are several moving parts, which could change at any point; but for health IT leaders, some of the key policy points to consider are:

  • The leadership positions at two healthcare federal agencies are likely to bring with them much different mentalities than what was seen in the previous administration. Recently-confirmed Health & Human Services (HHS) Secretary Tom Price, M.D. and Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma will emphasize de-regulation and putting more decisions in the hands of doctors and patients, rather than the federal government. Both Price and Verma have talked about this in recent Senate hearings.
  • The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which was passed with bipartisan support, seems safe. MACRA launched its first reporting period in January 2017 in which eligible Medicare clinicians will be reporting to a Quality Payment Program that determines a physician’s reimbursement based on the high quality, efficient care they provide that’s supported by technology. The MACRA law was enacted in order to sunset the constant “patches” to the never-funded SGR (sustainable growth rate) law; that means that any overturning of MACRA would require Congress to re-fund what could be more than $250 billion that would have to be recouped—an immense amount of federal funding that would pose challenges for anyone considering repealing MACRA.
  • Other value-based purchasing and accountable care payment programs have a bit of a murkier picture. Accountable care organizations (ACOs), many of which were stemmed from the very Affordable Care Act (ACA) that Trump is trying to “repeal and replace,” have their share of skeptics. Meanwhile, Secretary Price has been outspoken in the past on not forcing providers—especially physicians—into bundled payment programs.
  • Overall, there has been a strong desire from the new administration to reduce the burden that health IT puts on doctors. This was also a priority of the prior administration’s federal healthcare leaders, but coupled with the objective of Trump and his cabinet to de-regulate, it carries more teeth this time around.
  • The future role of the Office of the National Coordinator for Health Information Technology (ONC), the federal government’s health IT arm, also is cloudy. While no one expects the agency to be dismantled, the administration will have to name a new National Coordinator for Health IT at some point while current ONC staffers wait for more direction. The ONC might also see major funding cuts, based on priorities of the new administration.

Different industry experts will have varying opinions on all of the above, but the sources interviewed for this story all agree on one broad concept: value-based healthcare will continue to march on. Jeffrey Smith, vice president of public policy, at the Washington, D.C.-based American Medical Informatics Association (AMIA), expects new senior federal healthcare agency officials to conduct a broad review of initiatives that are ongoing or fairly new. “I am anticipating perhaps a consolidation of a lot of work going on at CMMI [the Center for Medicare & Medicaid Innovation] and with it, potentially an opportunity to look at some of the drivers that have historically been plaguing documentation burdens,” says Smith. Indeed, CMMI has been a target of Republicans in the House in the past, who say the center, which was established as an added section of the ACA, has overstepped its definition in statutes. Brian Ahier, digital health evangelist at Salt Lake City, Utah-based Medicity, predicts that CMMI, “which many in Congress feel has not been accountable enough for the funds [they have received], will ultimately be defunded.”

Jeffrey Smith

As for the future of ACOs, Smith says that it’s “incredibly unlikely that any ACA repeal would include something like the [elimination of] the Medicare Shared Savings Program [a federal ACO model]. I say that because when you look at the balance sheet, the MSSP is not costing the government a lot of money and it is starting to pay dividends for those who have been in [the program] for a while.” Smith adds that there has been a big push to lower the bar for entry, in terms of what is defined as “nominal cost” for a qualifying alternative payment model (APM) under MACRA, “so you will see a push to make investments into having an ACO count as the [required] nominal cost. Whether or not HHS looks at that and will actually count it, well, that doesn’t look good on paper,” he says.

Farzad Mostashari, M.D., former National Coordinator for Health IT and current president and founder of Aledade, a Bethesda. Md.-based company focused on physician-led ACOs, agrees with Smith, noting that he recently spoke with a lead Republican staffer who said that ACOs “have been taken off of the ACA playing field and are now on a new playing field, which is called MACRA.” Mostashari says that for folks who are tangentially involved, there is an uncertainty as to what a repeal of the ACA might mean for the delivery systems part of it, but he feels that the next six months “will show an unsettling of those concerns as implementation moves forward.”

Health I.T. Considerations

Much has been made in recent months about how the new administration wants to reduce the burden that health IT puts on clinicians. The praise for electronic health record (EHR) adoption across hospitals and physician practices is there, but now it’s time to make sure these systems are not impeding patient care, they say. But what does this really mean, for health IT end users going forward?

Smith notes that people have been talking for a while about this notion of clinical documentation not getting better with technology. “I expect to see and hear organizations talking about E/M [evaluation and management] coding guidelines and looking anew at how we document care. Are we documenting for outcomes? The answer is no,” says Smith. “What do doctors hate most?” he asks. “You come out of those conversations with [complaints] around clinical documentation and quality reporting. Price and his staff were involved with the MACRA legislation, and they want to encourage organizations to move into a risk-sharing mode, so the question becomes, how do we improve the tools we have to allow for good doctors to be successful in this new APM paradigm?”

Key to anything related to health IT is ONC, amidst a Politico eHealth report in February which said that Congress had considered abolishing ONC as part of its work related to the 21st Century Cures Act, according to sources on the Hill. But, the report noted, “lawmakers gave HHS’s small health IT office more responsibility, making it more bureaucratically ingrained and harder to kill in the future.” This back-and-forth leads one to believe that ONC’s role as a convener will stay intact, but both Smith and Mostashari feel that the agency’s work will mostly be focused on specific health IT use cases, as well as moving forward with the Cures Act. “If there are specific goals that the administration has for the use of this massive infrastructure that’s now in place to achieve those goals, then they will want to have informed expertise at ONC,” says Mostashari, noting that the agency’s annual budget “has been basically frozen” for the better part of the last decade. These use cases might range from easing the quality reporting burden in MACRA, improving patients' access to their health records, and evolving the EHR certification program,” say Smith and Mostashari.

Farzad Mostashari, M.D.

In the end, with all this in mind, what kinds of plans can healthcare leaders move forward with now, in the current policy moment? John Poelman, executive director of the Accountable Care Learning Collaborative (ACLC), whose mission is to help accelerate the readiness of the industry to adopt accountable care, advises, “Do not ignore it. By not paying attention, you can really put yourself in a bad situation. Take time to learn about what’s going on. Pay attention to new programs and what’s going on in your market, and start learning from as many sources as you can,” he says.

Nonetheless, when asked if the new administration is as bullish on healthcare information technology as previous ones, Smith says that going back eight years, the promise of health IT “was just around the next bend, and you had leadership who believed that. Now, leadership is disappointed.” He adds that it would be uncharacteristic and unhelpful to not look at the progress to date, and not want to figure out ways to maximize and capitalize on that progress. “There is a feasible future in which the cheerleaders for health IT are no longer in power, and those in power are not necessarily the staunch advocates we have had in the past, but it would be irresponsible to walk away from what we have done so far, and not to look for ways to make what we have better,” Smith says. “Even if you think we have lemons, let’s look for ways to make lemonade.”


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NAACOS, AMA, Others Urge CMS to Reconsider MSSP Proposed Changes

September 21, 2018
by Rajiv Leventhal, Managing Editor
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The National Association of ACOs (NAACOS) and eight other healthcare stakeholder groups have sent a letter to the Centers for Medicare & Medicaid Services (CMS), expressing concerns about the federal agency’s proposed changes to the Medicare Shared Savings Program (MSSP).

In August, CMS proposed sweeping changes to the MSSP, by far the largest federal ACO model, with 561 participants. At the center of the proposed rule, called “Pathways to Success,” is a core belief that ACOs (accountable care organizations) ought to move more quickly into two-sided risk payment models so that Medicare isn’t on the hook for money if the ACO outspends its financial benchmarks.

Specifically, CMS is proposing to shorten the glide path for new ACOs to assume financial risk, reducing time in a one-sided risk model from the current six years to two years. This proposal, coupled with CMS’ recommendations to cut potential shared savings in half—from 50 percent to 25 percent for one-sided risk ACOs—will certainly deter new entrants to the MSSP ACO program. So far, the proposed rule has been met with varying degrees of scrutiny.

NAACOS, comprised of more than 360 ACOs across the U.S., is one association that has been actively pushing back on the CMS proposal. The group believes that ACOs need, and deserve, more time in one-sided risk models since it takes years to develop the necessary infrastructure to be successful. What’s more, NAACOS is of the belief that one-sided risk ACOs actually save far more money than CMS gives them credit for.

NAACOS and others—including the American Medical Association (AMA), Medical Group Management Association (MGMA), and Premier—said in a press release accompanying the letter to CMS that the proposed Pathways to Success program would create several positive changes and includes a number of improvements the value-based community has previously recommended.

However, the groups also explained their concerns about CMS’ proposals to reduce the time new ACOs have in shared savings-only models from six to two years and to decrease the shared savings rate from 50 percent to 25 percent. The letter urges CMS to instead allow more time for ACOs in a shared-savings only model and to apply a shared savings rate of at least the current 50 percent to ensure a viable business model.

The groups wrote, “The MSSP remains a voluntary program, and it’s essential to have the right balance of risk and reward to continue program growth and success. Program changes that deter new entrants would shut off a pipeline of beginner ACOs that should be encouraged to embark on the journey to value, which is a long-standing bipartisan goal of the Administration and Congress and important aspect of the Quality Payment Program.”

It remains to be seen how CMS will respond to the pushback from NAACOS and others of late, though up to this point CMS has taken a firm stance that upside risk-only ACOs have not been effective. Thus, the federal agency seems to be fine with these ACOs leaving the MSSP if they are unwilling to take on more risk.

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Check and Checkmate: Is the Debate Around the MSSP ACO Program About to Get Super-Heated?

September 12, 2018
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Will NAACOS’s just-published study turn the tables on senior CMS officials? Or will it be ignored?

Something really quite extraordinary happened this week: NAACOS, the Washington, D.C.-based National Association of Accountable Care Organizations, published, in the august journal Health Affairs, a study based on research that NAACOS leaders had commissioned from Dobson DaVanzo & Associates, a healthcare economics consulting firm. And, as Healthcare Informatics Managing Editor Rajiv Leventhal noted in his report, “Medicare’s largest ACO (accountable care organization) initiative—the Medicare Shared Savings Program (MSSP)—generated gross savings of $1.84 billion for Medicare from 2013 to 2015, nearly double the $954 million estimated by the Centers for Medicare and Medicaid Services (CMS),” according to the NAACOS/Dobson DaVanzo & Associates study.

And here’s what’s extraordinary about that: this is the first time in my memory that I’ve seen a national association of provider organizations commission independent research that directly contradicted federal government findings and statistics. Could this be the start of a major conflict over the direction of the MSSP program? The potential for actual conflict here is quite real. But first, let’s look at what NAACOS and Dobson DaVanzo found. As Leventhal noted, “The study, which used similar scientific methods as a 2018 peer-reviewed paper by Harvard researchers published in The New England Journal of Medicine, found that MSSP ACOs reduced Medicare spending by $541.7 million during the 2013 to 2015 timeframe, after accounting for shared-savings payments earned by ACOs.”

The MSSP is the largest value-based payment model in the U.S., growing to 561 ACOs with more than 350,000 providers caring for 10.5 million Medicare beneficiaries in 2018. Under current MSSP rules, new ACOs are eligible to share savings with Medicare for up to six years if they meet quality and spending goals but are not at financial risk for any losses. As such, CMS has been reiterating in recent months that these “upside risk-only” ACOs are costing the government money.

What’s more, as Leventhal noted, “To this point, in a recent proposed rule that has so far been met with varying degrees of scrutiny, CMS is proposing to shorten that glide path for new ACOs to assume financial risk, reducing time in a one-sided risk model from the current six years to two years. This proposal, coupled with CMS’ recommendations to cut potential shared savings in half—from 50 percent to 25 percent for one-sided risk ACOs—will certainly deter new entrants to the MSSP ACO program. Importantly, CMS has essentially said they don’t mind if upside-only ACOs that are costing the government money leave the program if they aren’t willing to take on more financial risk. CMS Administration Seema Verma said in a press call following the proposed rule’s release that ‘[Upside-only] ACOs have no incentive, at all, to reduce healthcare costs while improving outcomes, as they were intended.’ Nonetheless, MSSP ACO participants seemingly performed quite well in 2017, despite CMS’ claims that they have been largely ineffective. In sum, the 472 ACOs that were in this model last year achieved $314 million in net savings to Medicare in 2017 after accounting for bonuses paid from the government, and $1.1 billion overall.”

For the NAACOS leaders, the key element here is that, as the authors of the Health Affairs article pointed out, “Despite the positive 2017 results, gauging MSSP performance based on calculations using administratively derived spending targets (benchmarks) is simply not an accurate way to measure overall program savings. In fact, the published academic research on MSSP performance points to much higher savings than are suggested by the benchmarks.”

Explained further by the researchers, for its analysis of Medicare ACOs, “CMS calculates an initial risk-adjusted spending benchmark for each ACO based on its historical spending for a group of attributed Medicare beneficiaries; it then trends this benchmark forward to the current program year based on the national average growth in Medicare spending per beneficiary.” The article’s authors further point out that if an ACO’s spending is less than the benchmark, and has a savings rate of at least 2 percent—and the ACO meets MSSP quality thresholds—it earns a shared savings payment that is typically 50 percent of the calculated savings. CMS then calculates total MSSP savings as the sum of total savings for ACOs with spending below the benchmark, plus the sum of spending above the benchmark for ACOs that exceeded it. Using this method, CMS estimated MSSP savings of $954 million between 2013 and 2015. During this period, ACOs that saved money earned $1.3 billion in shared savings payments. CMS concluded that on a net basis, the program increased Medicare spending by $344 million between 2013 and 2015, according to the NAACOS analysis and Health Affairs commentary.

At this juncture, there is an obvious issue here, because CMS’s calculation method implicitly makes it difficult for ACOs to show progress, since savings are benchmarked against administratively derived targets, rather than actual savings. Who came up with that method, anyway???

And the implications of using such a method are clear. As the press release that NAACOS issued upon the publication of the Health Affairs article noted, “Despite the growing ACO track record of improving quality and saving Medicare money, CMS, in an August 17 proposed rule, moved to shorten the time new ACOs can remain in the shared-savings-only model from the current six years to two years. Data show ACOs need more than two years to begin showing the benefits of forming an ACO. That proposal, coupled with CMS’s move to cut shared savings in half — from 50 percent to 25 percent for shared-savings-only ACOs — would deter new Medicare ACOs from forming.”

What’s more, the press release quoted Stephen Nuckolls, CEO of Coastal Carolina Quality Care in New Bern, N.C., which includes 63 providers caring for 11,000 Medicare beneficiaries, as stating that “It takes time and money to transform entrenched care delivery practices in local communities and build the critical mass to successfully integrate care, manage risk, and improve quality while reducing spending growth. Unfortunately, the proposed changes will hold up the move to value-based care by significantly undermining the business case to voluntarily form new Medicare ACOs.” 

I take Mr. Nuckolls’s charge very seriously. I interviewed him recently, and as he noted in our interview, when asked the secret of his ACO’s success so far in the six-plus years in which Coastal Carolina Quality Care has participated in the MSSP program, “[I]t takes time for some of these strategies, such as population health, to pay off. Another thing that’s going on is that our care management program, I give credit for keeping our costs low and getting things in place. And in addition,” he told me, “we really made a lot of strides in our first contract cycle, specific to our market. All of our annual wellness visits and preventive care, we made our marks there and that positioned us well in our second contract cycle. And it just takes time, when you focus on the quality of care, for… when a greater percentage of your patients have their blood pressure under control, you’ll have fewer adverse events. And when you work to lower a1cs, that will avert events over time. And annual wellness visits, vaccinations, screening services—it costs money for screenings; and once you get things set up, that’s then in place. And care management services—when you go into your second contract cycle, you have some of those costs worked into your contract cycle the second time; so it takes time to achieve shared savings, and to get the staff to focus on the sickest population.”

What’s more, what Nuckolls told me in our interview reflects what virtually every ACO leader I and my colleagues at Healthcare Informatics have heard from ACO senior executives—that it takes several years to lay the foundations for ACO success.

What’s more, Nuckolls told me, the results revealed in this data review-based study and article are important, as they speak to “the policy point—organizations are truly saving the government money, even if it doesn’t immediately show on paper. The evidence doesn’t support the idea that ACOs should be kicked out because they have a bad benchmark. The true savings to the Medicare Trust Fund will then be less. And that’s what they need to focus on, achieving true savings to the government.”

So, the obvious question now is, what will happen next? Will CMS Administrator Seema Verma lash out against NAACOS, denouncing this “rival” analysis of MSSP ACO savings? Will she ignore it? Or will she reach out to NAACOS’s leaders, and attempt to find common ground, as the “Pathways For Success” program potentially threatens the expansion of the voluntary MSSP program? It feels as though a lot is hanging in the balance right now, because if the national association representing ACOs has just come out with what is implicitly a denunciation of CMS’s method for calculating ACO progress and success, that is a fairly major “j’accuse” that Administrator Verma and her fellow senior CMS and HHS officials would do well to consider carefully. So the next move on this chessboard is Ms. Verma’s. And who knows what that move might look like?

 

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Seema Verma’s Big Picture: Tough Love, ACO Acceleration, Interoperability, and Consumer Empowerment?

August 29, 2018
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Will CMS Administrator Seema Verma’s strategy of pushing hard on providers around ACO development and interoperability help to accelerate the shift to value-based healthcare—or will it backfire?

Whatever may come, CMS Administrator Seema Verma is standing steadfast in her “tough-love” stances towards providers when it comes to ACO development. As Healthcare Informatics Associate Editor Heather Landi wrote on Monday, “During a webinar sponsored by the Accountable Care Learning Collaborative Monday morning, Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma reiterated the agency’s focus on pushing healthcare providers in accountable care organizations (ACOs) to take on two-sided risk while also addressing CMS’s commitment to try to remove barriers to value-based care.”

Further, Landi wrote, “During the 30-minute webinar sponsored by ACLC, a Salt Lake City-based accountable care collaborative, Verma discussed the sweeping changes that CMS is proposing for the Medicare Shared Savings Program (MSSP), noting that ‘it is time to take the next step.’ On August 9, CMS proposed a rule that included major changes to the existing MSSP ACO program, with the goal to push ACO organizations into two-sided risk models by shortening the duration of one-sided risk model contracts. Referred to as “Pathways to Success,” CMS’ proposal looks to redesign the program’s participation options by removing the traditional three tracks in the MSSP model and replacing them with two tracks that eligible ACOs would enter into for an agreement period of no less than five years: the BASIC track and the ENHANCED track. Verma’s comments on Monday morning emphasized CMS’s firm stance on pushing healthcare providers to take on more risk, as well as CMS’s strategy of giving providers more flexibility—such as waivers around telehealth—as a reward to transitioning to value-based care.”

What’s more, Administrator Verma came to the webinar with data. As Landi reported yesterday, “For the 2016 performance year, the Next Gen ACO Model generated net savings to Medicare of approximately $62 million while maintaining quality of care for beneficiaries, according to CMS. Overall, that represents a net reduction of 1.1 percent in Medicare spending within that program, Verma said. The Next Gen ACO model began in January 2016 with an initial cohort of 18 participants. It should be noted that 15 out of the 18 NGACOs had prior Medicare ACO experience.

Verma was not shy about what she thought those metrics meant. “What this really shows is that these Next Gen ACOs are taking the highest levels of risk and they’ve managed to maintain quality while still lowering cost,” Verma said during the webinar. “Much of the savings achieved by the Next Gen ACOs were largely due to reductions in hospital spending and spending in skilled nursing facilities, and that’s very consistent with what we’ve seen with how other two-sided ACOs have achieved savings. We’re excited about this; we think it’s a very strong start.”

Good cop, bad cop?

I’m impossible not to contrast Verma’s statements about the Next Gen ACO program with how CMS characterized the proposal it released just three weeks ago, on August 9. On that date, as Managing Editor Rajiv Leventhal and Associate Editor Heather Landi reported, “The Centers for Medicare & Medicaid Services (CMS) is proposing a new direction for ACOs (accountable care organizations) in the Medicare Shared Savings Program (MSSP), with the goal to push these organizations into two-sided risk models.”

Further, they wrote, “Referred to as ‘Pathways to Success,’ CMS’ proposal, which has been expected for a few months, looks to redesign the program’s participation options by removing the traditional three tracks in the MSSP model and replacing them with two tracks that eligible ACOs would enter into for an agreement period of no less than five years: the BASIC track, which would allow eligible ACOs to begin under a one-sided model and incrementally phase-in higher levels of risk; and the ENHANCED track, which is based on the program’s existing Track 3, providing additional tools and flexibility for ACOs that take on the highest level of risk and potential rewards. At the highest level, BASIC ACOs would qualify as an Advanced Alternative Payment Model (APM) under the Quality Payment Program.”

And, Seema Verma has made numerous comments now in numerous speeches to numerous different healthcare groups, making it very clear that she is becoming impatient with the pace of change in U.S. healthcare, and is determined to do something about it—with the support of Health and Human Services Secretary Alex Azar, her boss.

Indeed, Verma’s first in a series of speeches around interrelated topics of value-based payment and care delivery, patient/consumer empowerment, interoperability, and technology advancement, came as early as the HIMSS Conference in Las Vegas, where, on March 6, she “spoke of the need to move forward to empower patients with their data and information, in remarkably personal terms, recounting an episode in which her husband had collapsed while the two of them were not together, and was rushed to an emergency department, for what turned out to be heart failure,” as I reported at the time.  In the wake of her husband’s health crisis, she experienced the difficulty of accessing her husband’s health record, as an authorized family member. And that experience, she said, particularly animated the development of the MyHealthEData initiative she was unveiling on that date.

“The reality,” Verma said, “is that once the information is freely flowing from patient to provider, the advances in coordinated, value-based care, will be greater than anything we could imagine today she said back in March. Things could have been different for my family if my husband could have authorized me to have his health records on his phone,” she said. “Or if he could have notified me that he was in distress. And better yet, maybe we could have predicted his cardiac arrest days before, if his watch could have tracked his health data, and sending that data to alert his doctor, and possibly prevent what happened. My husband is part of the 1 percent that survives his condition. We shouldn’t have to depend on chance” for that type of outcome, she emphasized.

The big picture: pushing on several levels at once?

It seems clear that Azar and Verma—certainly, with the help of Donald Rucker, M.D., National Coordinator for Health IT—are determined to acceleration the transition of U.S. healthcare providers into value-based healthcare, through a combination of different incentives, including a wide variety of carrots and sticks. And, not to mix too many metaphors here, but it also seems clear that her praise of the progress made by the Next Gen ACO program ACOs is evidently a “good cop” positioning, while she largely framed the relatively modest progress in the MSSP program in a “bad cop” sort of way, essentially telling MSSP ACO leaders that it was time to stop with upside-only risk, and move into two-sided risk as quickly as possible.

Of course, the risks in this kind of approach are significant. Not surprisingly, the National Association of ACOs (NAACOs) heaped scorn on the August 9 “Pathways to Success” proposal, with NAACOS CEO Clif Gaus saying in a statement released that evening, that “The administration’s proposed changes to the ACO program will halt transformation to a higher quality, more affordable, patient-centered healthcare industry, stunting efforts to improve and coordinate care for millions of Medicare beneficiaries.” According to Gaus, “The downside financial risk for patient care would be on top of the significant financial investments ACOs already make, jeopardizing years of effort and investment to improve care coordination and slow cost growth.” He continued, “CMS discusses creating stability for ACOs by moving to five-year agreements, but they are pulling the rug out from ACOs by redoing the program in a short timeframe with untested and troubling polices.”

So it seems to me that Azar, Verma, and Rucker, and their colleagues, are in a bit of a challenging place here, because even as the progress has been measurably stronger in the Next Gen ACO program compared with that in the MSSP program, even in Next Gen, it hasn’t been spectacular. Meanwhile, Verma’s attempts to push down harder on the levers of payment and regulation in order to turbocharge ACOs, could very easily backfire, causing more ACOs to leave the MSSP program than to switch to two-sided risk.

So this is a delicate, complicated moment. Will “tough love” and “good cop, bad cop” strategies at HHS and CMS really work? Only time will tell—but this feels like an important moment in the evolution of value-based healthcare, with no clear answers as to how HHS (the Department of Health and Human Services) and CMS officials might be successful in forcing transformational change forward, at a time when the coming U.S. healthcare cost cliff is looming more closely than ever before, just up a head. As Bette Davis said, as Margo Channing, in Joseph L. Mankiewiecz’s 1950 film “All About Eve,” “Fasten your seat belts—it’s going to be a bumpy night!”

 

 

 

 

 

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