On Oct. 16, the College submitted comments to the Centers of Medicare and Medicaid Services (CMS) on the agency's proposed rule addressing the Medicare Shared Savings Program (MSSP) and Accountable Care Organizations (ACOs) Pathways to Success, offering detailed feedback related to the BASIC and ENHANCED participation tracks, benchmarking methodology, waivers and beneficiary incentives and ACO and standalone Part D plan collaboration.

The proposed rule reflects an evolution in the MSSP for ACOs, which has been a key driver for primary care clinicians to adopt value-based payment in the Medicare fee-for-service program in recent years. The ACC believes that alternative payment models (APMs) have significant potential to enhance patient care and shares CMS' goals of improving quality of care while lowering costs for Medicare and Medicaid. However, the College believes that in refining the MSSP, ACOs should reflect the appropriate patient populations and provide a complete picture of care provided by all clinicians involved, including specialist clinicians. The College is strongly concerned that the rapid assumption of significant levels of risk by ACOs will discourage new participants and impede current MSSP ACOs' ability to make patient-centered infrastructure investments that are necessary for successful participation.

The ACC is committed to working with CMS and providers to promote success in the value-based payment environment. The College looks forward to ongoing collaboration with the agency to create opportunities for cardiovascular clinicians to participate in the MSSP and other APM initiatives. Read the full comment letter here. Assess whether your practice is well-suited for APM participation through the ACC's APM Framework.

Keywords: ACC Advocacy, Fee-for-Service Plans, Accountable Care Organizations, Medicaid, Centers for Medicare and Medicaid Services, U.S., Medicare, Health Expenditures, Patient Care, Quality Improvement, Primary Health Care

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