RE: Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations
Administrator Tavenner,
The Alliance of Specialty Medicine and its member organizations thank you for the opportunity to provide input
on proposed changes to Medicare Share Savings Program (MSSP) Accountable Care Organizations (ACO). The
Alliance is a coalition of 14 medical specialty societies representing more than 100,000 physicians and surgeons
dedicated to the development of sound federal healthcare policy that fosters patient access to the highest
quality specialty care.
Interest in the MSSP ACO program is growing among specialty physicians as a way to improve quality, resource
use, and better coordinate care for our patients, particularly those with complex health conditions. Noteworthy
attributes of the ACO program are expanded access to meaningful and actionable patient data, and a robust
infrastructure that fosters improved communication among providers of care.
We very much appreciate CMS’ willingness to meet with the Alliance and its individual members on multiple
occasions over the past two years to listen to our concerns regarding challenges that specialists face in regards
to the MSSP. We are encouraged that the proposed policies in this rule seek to improve the MSSP ACO program
in ways that encourage meaningful specialist participation. In particular, we thank CMS for addressing one of our
key concerns by revising how certain physician specialties are considered in the beneficiary assignment process
to prevent exclusivity to one ACO.
In the paragraphs below, we outline our strong support for key proposals that have a direct impact on
specialists’ ability to engage in the MSSP ACO model, as well as make additional recommendations that would
further encourage meaningful specialty medicine participation in the program.
Assignment of Medicare FFS Beneficiaries: Consideration of Physician Specialties and Nonphysician Practitioners in the Assignment Process
One of the biggest challenges specialty physicians have faced with the MSSP is their inability to participate in
more than one ACO. Participation in multiple ACOs is critical for specialty physicians, particularly those in areas
with a high concentration of ACOs that anchor to a particular hospital or hospital system. The difficulty with the
current assignment process is CMS’ requirement that ACO participants billing for “primary care services” must
remain exclusive to a single ACO since those services are used by CMS to assign beneficiaries to the ACO.
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