Healthcare Stakeholders Comment on ACO Benchmarking Rule | Healthcare Informatics Magazine | Health IT | Information Technology Skip to content Skip to navigation

Healthcare Stakeholders Comment on ACO Benchmarking Rule

March 29, 2016
by Rajiv Leventhal
| Reprints

Several organizations have submitted joint comments to the Centers for Medicare & Medicaid Services (CMS) in response to the agency’s proposed rule it released earlier this year to modify the benchmark rebasing methodology for accountable care organizations (ACOs) in the Medicare Shared Savings Program (MSSP).

The joint comments represent the collective views of organizations representing physicians, hospitals, medical group practices, academic medical centers and nearly all existing MSSP ACOs, according to a statement released by the Charlotte, N.C.-based Premier, Inc.

In its late January announcement regarding the modifications, CMS said it was looking to leverage the new proposed rule in order to modify the process for resetting the MSSP program’s benchmarks, which are used to measure ACO performance. Among the key elements in the changes that the agency was proposing:

  • Recognizing that health cost trends vary in communities across the country by using regional, rather than national, spending growth trends when establishing and updating an ACO’s rebased benchmark
  • Adjusting an ACO’s rebased benchmark when it enters a second or subsequent agreement period by a percentage (increased over time) of the difference between fee-for-service (FFS)
  • Spending in the ACO’s regional service area and the ACO’s historical spending, which will provide a greater incentive for continued ACO participation and improvement
  • Giving ACOs time to prepare for benchmarks that incorporate regional expenditures by using a phased-in approach to implementation

In the recent comments from 22 healthcare stakeholders to CMS Acting Administrator Andy Slavitt, signers expressed strong support for CMS’ proposal to incorporate regional cost data into benchmarks, arguing that the current method of basing benchmarks solely on ACO-specific historical spending penalizes ACOs for performing well in the past, and forces them to chase increasingly more challenging benchmarks in subsequent agreement periods. By blending historical and regional cost data, commenters note that CMS will improve the long-term viability of the program by attracting new providers, while also improving the odds of retaining current participants.

However, commenters also noted that there remains a critical need to make additional changes to ensure the future of the program. In particular, commenters recommend that CMS:

  • Finalize, with modification, blending ACO historical and regional cost data into ACO benchmarks;
  • Provide ACOs with maximum flexibility and choices related to transitioning to benchmarks that comprise a component of regional cost data;
  • Focus on comparing ACO performance relative to FFS Medicare by excluding ACO-assigned beneficiaries (for all ACOs in the region) from the regional beneficiary population;
  • Honor the current policy that accounts for savings in rebased benchmarks, rather than punish ACOs that worked hard to earn savings in previous agreements; and
  • Modify and enhance the proposal to reopen ACO determinations to include greater opportunities for ACOs, especially when CMS errors are the cause, and shorten the timeframe from four to two years

“Our recommendations reflect our unified expectation and desire to see the MSSP achieve the long-term sustainability necessary to enhance care coordination for Medicare beneficiaries, lower the growth rate of healthcare spending and improve quality in the Medicare program,” wrote the comment letter signers. “Given our analyses show ACOs on average spend three percent less than comparable fee-for-service expenditures, it should remain a priority of the Secretary to refine the model in ways that will promote further program growth.”

Separately, although not addressed in the proposed rule, the commenters also state in their letter that as CMS heads into rulemaking for the Medicare Access and CHIP Reauthorization Act (MACRA), the agency should designate all MSSP ACOs as qualifying alternative payment models (APMs) under MACRA. This would allow physicians participating in all MSSP ACOs to qualify for MACRA APM incentive payments, provided they meet the threshold levels of revenue or patient participation required by the law.

Get the latest information on Health IT and attend other valuable sessions at this two-day Summit providing healthcare leaders with educational content, insightful debate and dialogue on the future of healthcare and technology.

Learn More



ONC Roundup: Senior Leadership Changes Spark Questions

The Office of the National Coordinator for Health IT (ONC) has continued to experience changes within its upper leadership, leading some folks to again ponder what the health IT agency’s role will be moving forward.

Media Report: Walmart Hires Former Humana Executive to Run Health Unit

Reigniting speculation that Walmart and insurer Humana are exploring ways to forge a closer partnership, Walmart Inc. has hired a Humana veteran to run its health care business, according to a report from Bloomberg.

Value-Based Care Shift Has Halted, Study Finds

A new study of 451 physicians and health plan executives suggests that progress toward value-based care has stalled. In fact, it may have even taken a step backward over the past year, the research revealed.

Study: EHRs Tied with Lower Hospital Mortality, But Only After Systems Have Matured

Over the past decade, there has been significant national investment in electronic health record (EHR) systems at U.S. hospitals, which was expected to result in improved quality and efficiency of care. However, evidence linking EHR adoption to better care is mixed, according to medical researchers.

Nursing Notes Can Help Predict ICU Survival, Study Finds

Researchers at the University of Waterloo in Ontario have found that sentiments in healthcare providers’ nursing notes can be good indicators of whether intensive care unit (ICU) patients will survive.

Health Catalyst Completes Acquisition of HIE Technology Company Medicity

Salt Lake City-based Health Catalyst, a data analytics company, has completed its acquisition of Medicity, a developer of health information exchange (HIE) technology, and the deal adds data exchange capabilities to Health Catalyst’s data, analytics and decision support solutions.