December 1, 2020
Written by Farzad Mostashari
Veteran policy wonks were compulsively refreshing their browsers set to the Federal Register website last Thursday at 4:15 PM, hoping for some light reading before the July 4th long weekend. Specifically, they were waiting for the new proposed rule from CMS on revisions and updates to the Medicare Shared Savings Program. It’s an issue that many in the health care transformation field have been following closely (I co-authored a Brookings Policy Brief last month offering suggestions on where we thought the policy should go).
While we didn’t get the long-awaited “ACO 2.0” rule, we did get some nuggets of ACO-related policy news in the annual Physician Fee Schedule proposed rule that was released instead. For those of you who already have your beach reading set for this summer, I’ve pulled out three key takeaways from the 609-page document:
1) Evolution, Not Revolution, Concerning Quality Measures
For better or worse, there is a lot of continuity between the quality measurement framework proposed here and the MSSP rule promulgated three years ago. Some measures have been retired because the evidence no longer supported them (e.g. lipid control to a specific LDL level), and others were duplicative of existing measures. In total, eight measures were dropped, but 12 new measures were added, notably including all-cause unplanned admissions for certain populations, and skilled nursing facility readmissions. These new measures will be “report only” for their first year in 2015. The proposed rule would also award bonus points for quality improvement (not just performance) in each of the existing four ACO quality measure domains
2) Missing an Opportunity on Quality Reporting
Unfortunately, CMS did not propose any new requirements regarding EHR- or registry-based reporting for MSSP – an extremely disappointing outcome, given the major problems that exist with the current Group Practice Reporting Option GPRO web interface. CMS “estimate[s] that, on average, it will take each group practice 79 hours to submit quality measures data via the GPRO web interface,” but anyone who has dealt with the system knows that the time commitment vastly exceeds that number, and a more streamlined, efficient platform is necessary. The solution is not to scale back the number of patients per measure (from 411 to 268)- but rather to move away from sampling- and chart review- based quality measurement altogether.
3) “Volume to Value” Evidence Mounts
The proposed rule did have some very encouraging news in the proposals for the Value-based Modifier (VBM) and Chronic Care Management (CCM) regulations. As expected, the VBM increased from 2 to 4 percent, and will be phased in to all practitioner groups by 2017. The CCM regulation allows $41.92 to be billed to Medicare once a month, for each qualified patient with two or more chronic conditions. It requires the practice to provide 24/7 patient access, secure messaging, a designated provider, medication management, a comprehensive plan of care, care transitions and community supports, as well as a 2014 certified EHR accessible to all providers within the practice—all components of a comprehensive ACO strategy.
Overall, the proposed PFS rules offer some encouraging signs about where Medicare is headed – away from the old fee-for-service model and towards rewarding ACOs that deliver the best outcomes. Here at Aledade, we are working to help make that transformation happen, and will be watching and responding to CMS as it continues to lay out the new rules of the road.