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    September 20, 2018  

    The Honorable Seema Verma
    Centers for Medicare & Medicaid Services
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building, Room 445–G
    200 Independence Avenue, SW
    Washington, DC 20201

    Re: Strengthening the Medicare Shared Savings Program 

    Dear Administrator Verma:

    The undersigned organizations write to express appreciation for efforts to update the Medicare Shared Savings Program (MSSP) and to request the agency move forward with efforts to modernize the MSSP and ensure its long-term success. We also write to provide additional perspective from new data on Accountable Care Organization (ACO) performance and to highlight two specific areas that could result in unintended consequences that diminish the overall shift to value-based care and payment and were included in the recent MSSP proposed rule, entitled Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations – Pathways to Success, published in the Federal Register on August 17, 2018. Our recommendations reflect our unified desire to see the MSSP achieve the long-term sustainability necessary to enhance care coordination for millions of Medicare beneficiaries, lower the growth rate of healthcare spending and improve quality in the Medicare program. 

    The ACO model is a market-based solution to fragmented and costly care that empowers local physicians, hospitals and other providers to work together and take responsibility for improving quality, enhancing patient experience and reducing waste to keep care affordable. Importantly, the ACO model also maintains patient choice of clinicians and other providers. While the origins of Medicare ACOs date back to the George W. Bush Administration, the MSSP has grown considerably in recent years and now includes 561 ACOs, covering 10.5 million beneficiaries. ACOs have been instrumental in the shift to value-based care and a central part of the ACO concept is to transform healthcare through meaningful clinical and operational changes to put patients first by improving their care and reducing unnecessary expenditures. 

    These transformations are significant and, as such, require time for implementation and to produce measurable results. ACOs are investing millions of dollars of their own capital to make these care improvements, even though Medicare does not recognize these start-up and ongoing investments in its calculations of ACO savings, losses, and costs. Further, the benefits of these transformations extend beyond the ACO’s attributed Medicare fee-for-service patient population and have a broader effect on Medicare Advantage beneficiaries and even patient populations beyond Medicare. 


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