The structure of the current Medicare Shared Savings Program (MSSP) — the Centers for Medicare and Medicaid Services (CMS) accountable care organization (ACO) trial — has posed challenges for participating organizations, notes the Premier healthcare alliance of 2,900 U.S. hospitals and nearly 100,000 other providers in a letter to CMS Administrator Marilyn Tavenner.

Premier, a public company, seeks to use a private-sector analytics-focused approach to transform care delivery, and not surprisingly echoed the American Hospital Association’s earlier letter to CMS about the problem with timely and accurate data in the government’s ACO trial.

A certain amount of “churn” of patients moving in and out of an ACO is common to all such systems, Premier acknowledged. However, unlike private payor and Medicare Advantage ACO models, the patients in CMS’s MSSP are assigned retrospectively by CMS so that neither the patient nor the provider can easily tell who is or isn’t in the ACO at the time care is provided. In addition, unlike most private plans that narrow care networks to encourage staying within the ACO for care, the MSSP patients can see any provider they want and they can opt out of sharing their data while still remaining within the ACO.

Premier’s Partnership for Care Transformation (PACT) collaborative is the largest population health collaborative in the country and the company well knows how important timely and accurate patient data is if the goal is to effectively manage costs and improve outcomes while also managing risk. Among its recommendations to CMS were:

• Make the application process easier, the costs of joining lower and the reporting requirements simpler.
• Until data delivery from the government is more timely, consider ways to mitigate the risk ACOs going into their second contracting period will need to take on.
• Expand advance payment to more providers and larger facilities so that they can make investments needed for population health.
• Ask beneficiaries to pick their ACO rather than assigning them to an ACO and try to keep patients assigned to one ACO in one year in the same ACO the next year.
• Recognize the important nature of data in care management and have patients who don't want their data shared opt out of ACO participation completely, not just out of the data sharing.
• Improve data with more details, including age and gender, that can help ensure accurate comparison's are made, especially as baby boomers become newly Medicare eligible and dilute numbers on older patients.
• Make the 2 percent minimum savings rate the same for both small ACOs that have populations just above 5,000 and large ACOs with more than 50,000 beneficiaries. Currently, small ACOs need to hit a higher savings rate of 3.9 percent.