RE: Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations Pathways to Success

Dear Ms. Verma,

On behalf of more than 100,000 specialty physicians from 15 specialty and subspecialty societies, and
dedicated to the development of sound federal health care policy that fosters patient access to the highest
quality specialty care, the undersigned members of the Alliance of Specialty Medicine (the “Alliance”)
write in response to proposals aimed at redesigning and providing a new direction for the Medicare
Shared Savings Program (MSSP) Accountable Care Organizations (ACOs).

General Concerns

Specialist Participation in ACOs

Despite a recent Medicare Payment Advisory Commission (MedPAC) analysis that found sixty percent
(60%) of ACO-participating physicians are specialists, the Alliance remains concerned that many ACOs
have adopted “narrow networks” to inappropriately limit specialty physician participation. The lack of
“network adequacy” standards allows this primary care-dominated model to essentially “bar” the
participation of specialists, even when specialty physicians express an interest in joining the model.

Some ACOs have told specialists that the items and services related to the care they deliver is “expensive”
and would be difficult to control, potentially having a negative impact on cost and resource use. In
addition, the quality measures ACOs are held to are primary-care focused, leaving specialists with little
opportunity to improve care and quality scores. Specialists that are participants report their engagement
as limited, if at all. In fact, the vast majority of specialists have been unaware of their ACO participation
status until they received notification through CMS’ Quality Payment Program (QPP).

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Read full letter here