Allison Brennan Discusses Impacts of Certain Proposed Changes to the MSSP

There are some proposed changes to the Medicare Shared Savings Program (MSSP) that may be favorably or not depending on the accountable care organization (ACO) and its situation, said Allison Brennan, MPP, senior vice president of government affairs for the National Association of ACOs.

What are some proposed changes to the MSSP that some ACOs might see as an opportunity, but others might view as a challenge?
There’s a lot of complexity in this program, and as we look at the impact of certain proposals on various ACOs it can affect ACOs differently. So, a good example of this is benchmarking, where we see a proposal that would change how CMS incorporates a component of regional expenditure data into the benchmark. And the goal of that policy is to avoid comparing ACOs only to their historical performance as times moves on.

And this is something that we’re very supportive of—moving away from just looking at those historical expenditures. If we remain just looking at historical expenditures, eventually they’ll get so low that people can’t achieve savings and always beat their past performance. So, a way to fix that problem is to increasingly compare ACOs to other providers in their region. Some of the proposals in the benchmark change how CMS would incorporate that regional comparison into the benchmark. So, certain ACOs may view that favorably and other ACOs may not view it favorably, depending on how they compare to their regional costs.

Another example is risk adjustment. We are definitely pleased to see some of the proposals CMS put forward with risk adjustment. But some of the other elements of the proposal will be harmful to certain ACOs, so, we’re making some recommendations for CMS to finalize some of elements of the risk adjustment proposals and then modify other elements.
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