RE: Accountable Care Organizations
Dear Chairman Crosson,
The Alliance of Specialty Medicine and its member organizations thank you for the opportunity to
provide input into the Commission’s ongoing efforts to improve the Medicare Shared Savings Program
(MSSP) and Accountable Care Organizations (ACOs). The Alliance is a coalition of 13 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 and ACOs 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 Medicare ACO program are expanded access to meaningful
and actionable patient data, and a robust infrastructure that fosters improved communication among
providers of care. The forthcoming implementation of programs established under the Medicare Access
and CHIP Reauthorization Act (MACRA) only furthers the desire for specialist engagement in such
models.
As you know, CMS recently revised how certain physician specialties are considered in the beneficiary
assignment process, a welcome change that allows most specialists to participate in multiple Medicare
ACOs rather than be exclusive to one.
Despite some favorable changes in the Medicare ACO program, specialty physicians face unique
challenges. As the Commission continues to study this alternative payment and delivery model, we
encourage a closer look at the role of specialty physicians and how their engagement can be improved.
We outline some of our most pressing concerns below.
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