Medicare Compliance & Reimbursement
CMS Proposes a MSSP Revamp for CY 2023
Get ready for ACOs to become front and center next year. You may have noticed that COVID revealed a plethora of equity issues that have greatly factored into Medicare’s policymaking over the last year. As part of the 2023 rulemaking cycle, more proposals are on the table — and this time the spotlight is on the Medicare Shared Savings Program (MSSP). Context: On July 29, the Centers for Medicare & Medicaid Services (CMS) published the calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) proposed rule in the Federal Register. CMS’ latest opus aims to reimagine the MSSP, which began in 2012, with a myriad of quality and social reforms to improve Accountable Care Organization (ACO) participation. “Integrated coordinated, whole-person care — which addresses physical health, behavioral health, and social determinants of health — is crucial for people with Medicare, especially those with complex needs,” said Meena Seshamani, MD, CMS Deputy Administrator and Director of the Center for Medicare in a release on the rule. “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.” Remember: The MSSP allows those involved in beneficiary care — hospitals, providers, and suppliers — the option to voluntarily create an ACO. “An ACO agrees to be held accountable for the quality, cost, and experience of care of an assigned Medicare fee-for-service (FFS) beneficiary population,” reminds CMS guidance. There are various tracks in the MSSP that offer ACOs a differentiated arrangement depending on the needs of their organization. Furthermore, another goal of the coordination of care in the ACO “is to ensure that patients get the right care at the right time, while avoiding unnecessary duplication of services and preventing medical errors,” CMS says. “When an ACO succeeds both in delivering high-quality care and spending health care dollars more wisely, the ACO will share in the savings it achieves for the Medicare program.” Check Out These 5 MSSP Proposals According to the proposed rule, ACO participation has “plateaued,” and CMS would like to beef up participation in the MSSP. On top of that, statistics show that “Black (or African American), Hispanic, Asian/Pacific Islander, and American Indian/Alaska Native beneficiaries are less likely to be assigned to a Shared Savings Program ACO than their Non-Hispanic White counterparts,” a fact sheet on the proposed rule says. These reasons and others have led CMS to propose several changes to the MSSP and ACOs that encourage equitable access to coordinated, affordable care. Take a look at five proposals on the table: 1. Investment program: Medicare providers who care for underserved and rural populations often need funding to kickstart their ACOs. The agency proposes to offer “low revenue ACOs, inexperienced with performance-based risk Medicare ACO initiatives, that are new to the Shared Savings Program (that is, not a renewing ACO or a re-entering ACO), and that serve underserved populations” advance investment payments to help establish their arrangements, the fact sheet indicates. CMS would base the proposed program off the existing CMS Innovation Center ACO Investment Model (AIM) and would require a supplemental application, the rule suggests. 2. Health equity adjustment: CMS also wants to bolster excellent care by adding a health equity adjustment to the performance category scoring. “Under the proposed rule, an ACO’s quality performance score will be adjusted for health equity bonus points based on the ACO’s high performance on quality measures and providing care for a higher proportion of underserved or dually eligible beneficiaries,” explains partner attorney Kim Roeder with King & Spalding LLP in the law firm’s Health Headlines newsletter. 3. Downside risk: CMS proposes to offer smaller ACOs more time to transition to models with more downside risk. This policy aims to encourage more underserved and rural provider participation, the fact sheet says. 4. Administrative burdens: Similar to past policies, CMS wants to cut ACOs’ paperwork hassles. Proposed changes include removing the ACO marketing material review requirement; updating data sharing; reducing beneficiary notifications about value-based care; and getting rid of the ACO requirement on SNF 3-day rule waivers. 5. Benchmarking: CMS proposes “a number of adjustments to the ACO benchmarking methodology to address such matters as reducing the impact of ACO performance on ACO historical benchmarks and providing incentives for ACOs to care for medically complex, high-cost beneficiaries and to remain in the MSSP,” Roeder expounds. Public input: CMS is accepting commentary on the MSSP proposals through Sept. 6 at www.regulations.gov/document/ CMS-2022-0113-0001. Resource: Review the proposed rule at www.govinfo.gov/ content/pkg/FR-2022-07-29/pdf/2022-14562.pdf.
Medicare Compliance & Reimbursement
- Medicare Shared Savings Program:
CMS Proposes a MSSP Revamp for CY 2023
Get ready for ACOs to become front and center next year. You may have noticed [...] - Fraud & Abuse:
Federal Enforcers Fixate on Clinical Labs
Ensure your lab claims are medically necessary — or pay the price. Your practice likely [...] - ICD-10 Coding:
Prepare Now for New SDoH Codes Starting Oct. 1
Plus: Check out SDoH and noncompliance code revisions, too. The Centers for Medicare & Medicaid [...] - Reader Questions:
Utilize Free Medicare Billing Advice
Question: Our primary care practice has seen an uptick in denials of our Part B claims. [...] - Reader Questions:
Pocket This Advice on How to Properly Dispose of PHI
Question: We have some student helpers working at our practice this summer. We were going to [...]
