Dr Katherine Schneider: MSSP Proposed Changes Will Be a Step Back on Path to Value

The proposed changes to the Medicare Shared Savings Program could prevent the program from driving broad change to value-based care across the country, according to Katherine Schneider, MD, MPhil, FAAFP, president and CEO of Delaware Valley ACO.

What is the greatest challenge you see with CMS’ proposed changes to the MSSP?
The Pathways to Success proposed rules changes have a couple of really major concerns, and I think the biggest one is really the impact not on folks like me, who’ve been in the program for 5 years, but it’s on those who are either new entrants or are considering getting in.

Two things. Number 1, the accelerated pace to taking downside risk, the proposal of it being 2 years is just not viable at all. Having gone through being in the program, and actually I was part of the demonstration project 10, 15 years ago that was the precursor, you don’t even know your first-year performance until after the time that you would have to commit to taking downside risk in year 3. That’s just not viable. Let alone have any cash flows. Certainly not viable from a responsible business due diligence perspective.

And the second is the attractiveness of coming in. The gain sharing proportion being reduced from 50% to 25%. I can say with absolute certainty that if those 2 rules had been in effect and with the lack of ability to do things like a Medicare Advantage plan can do in terms of benefit design, in terms of risk adjustment, there’s no way we would have gone into the program. And we’re one of the biggest ACOs in the country. And we committed to this model. And I personally believe that it’s capable of driving broad change across the country in a way that niche programs really can’t do.

So, my biggest concern is really that if we focus just on, “well, the program will just serve a couple of high-performing ACOs,” you’re going to have a great program that nobody is in. And that’s a real concern.

There are other smaller issues around operational things, like beneficiary notifications, going backwards on that. But I really think holistically, for the country, the proposed rules are going to result in a step backwards on the path to value.
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