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Association Comments on Proposed MSSP Changes

In an Oct. 16 letter, America’s Essential Hospitals urged the Centers for Medicare & Medicaid Services (CMS) to promote stability and predictability for accountable care organizations (ACOs) in the Medicare Shared Savings Program (MSSP), while also allowing hospitals more time to participate in the savings-only track of the program.

The letter was sent in response to a proposed rule that would alter the MSSP and ACOs. The proposed rule would overhaul participation tracks in the MSSP to create a “glide path” along which ACOs would transition from a reward-only model to a two-sided model with risk and the potential for greater rewards.

The association urged CMS to promote stability and predictability for ACOs in the MSSP, while allowing hospitals more time to participate in the savings-only track of the program. In its comments, America’s Essential Hospitals also encouraged CMS to:

  • restore the shared savings rates to 50 percent for all ACOs in the BASIC track;
  • further examine the differences in ACO performance before imposing participation options based on Medicare revenue;
  • continue to refine measures used to establish ACO quality performance standards to ensure an accurate representation of quality of care;
  • recognize the challenges essential hospitals face in implementing certified electronic health record technology when setting thresholds for the MSSP;
  • finalize its proposal to allow choice in beneficiary assignment on an annual basis by all ACOs; and
  • continue to refine its risk-adjustment methodology to account for changes in health status of ACO assigned beneficiaries over time.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a policy associate at America's Essential Hospitals.

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