PFS Proposed Rule includes MSSP Changes Benchmarks to Encourage Participation, Advance Equity

Last Thursday, the Centers for Medicare and Medicaid Services (CMS) published the proposed 2023 physician fee schedule (PFS) which included an overhaul to the agency’s strategies on accountable care organizations (ACOs) through the Medicare Shared Savings Program (MSSP).

In February, CMS pulled the Accountable Care Organizations Transformation Track, which would have given a few rural ACOs advance payments, because the agency was working on more broad-ranging proposals. According to Inside Health Policy, the agency said that a number of the proposed changes in the 2023 PFS would improve equitable access to ACOs, not just for rural populations but also racially marginalized demographics who have generally struggled to find access to ACOs. From Meena Seshamani, CMS deputy administrator and the director of the Center for Medicare:

If finalized, the proposals in this rule will advance equity, lead to better care, support healthier populations and drive smarter spending of the Medicare dollar.

CMS projects that the changes could lead to $650 million in higher shared savings payments to ACOs, Modern Healthcare reports. The agency aims to accomplish this by offering shared savings payments to some low-revenue ACOs and by allowing more flexibility for ACOs that take on more risk. Under the proposed rule, eligible ACOs would receive a one-time payment of $250,000 and quarterly payments based on enrollee need for two years. The agency would recoup payments once the participating ACO begins to earn shared savings.

Furthermore, CMS plans to modify benchmark methodology by incorporating a prospective, external factor into ACO benchmarks in addition to a prior savings adjustment in the historical benchmarks for established participants. From the CMS Fact Sheet:

We believe these proposed modifications could serve as ‘stepping stones’ to a longer-term approach to the benchmarking methodology.

ACO representative group, the National Association of ACOs (NAACOS) lauded the proposal and its centering of ACOs, championing the PFS as a gateway for increased participation in ACO programs and attracting participating providers. From NAACOS President and CEO Clif Gaus:

Importantly, CMS projects today’s proposed changes would save Medicare more than $15 billion and yield $650 million in higher shared savings payments to ACOs. We know the most successful alternative payment models (APMs) are when providers are held accountable for patient outcomes for the entire year, as ACOs do.

The PFS also includes a push to expand access to behavioral health services, cancer screenings and dental care for rural and underserved populations. According to Healthcare Finance News, CMS is proposing to allow licensed professional counselors and other types of behavioral health practitioners to provide health services under relaxed supervision. Also, the agency aims to pay for clinical psychologists and licensed clinical social workers to provide integrated behavioral health services as primary care.