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    October 14, 2021  

    The Honorable Chiquita Brooks-LaSure
    Centers for Medicare and Medicaid Services
    Hubert H. Humphrey Building
    200 Independence Avenue, S.W.
    Washington, DC 20201

    RE: Request to provide MSSP ACOs an option to use pre-pandemic years to set benchmarks

    Dear Administrator Brooks-LaSure:

    The undersigned organizations are committed to advancing value-based care and the role that Accountable Care Organizations (ACOs) play in that critical transformation of our health care system. We write to express our concern with how existing agency policies to set financial spending targets or benchmarks for ACOs are not fair for many because of the ongoing COVID-19 pandemic. The Centers for Medicare & Medicaid Services (CMS) has worked hard since early last year to give our health system and providers the tools needed to fully combat the ongoing pandemic. We greatly appreciate those efforts which have included modifications to value-based care programs, such as those for Medicare’s largest alternative payment model (APM), the Medicare Shared Savings Program (MSSP). However, further policy changes are needed to ensure the shift to value is not derailed by the highly unusual circumstances of the pandemic.


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