- The American Medical Group Society (AMGA) recently recommended CMS focus on improving accountable care organizations (ACOs) and the Medicare Shared Savings Program (MSSP) rather than put forth a new direct provider contracting (DPC) model.
AMGA submitted the recommendations to CMS Administrator Seema Verma in response to a Request For Information (RFI) seeking stakeholder feedback about whether the federal agency should develop a new DPC model or strengthen the existing MSSP program.
AMGA said CMS should focus on improving MSSP over starting a new primary care initiative.
“While it is encouraging that CMS is interested in developing new models that are based on primary care, patients, providers, and the Medicare program would be better served by building on the considerable investments already made in the ACO program,” said AMGA President and CEO Jerry Penso, MD.
“We’re concerned that if CMS moves forward with a DPC model, it may compromise the MSSP by reducing the number of providers and beneficiaries who participate in a program that is based on the same goals as a potential DPC model,” he continued.
According to CMS, the DPC model would be duplicative of existing CMS models — including MSSP and Comprehensive Primary Care Pulse (CPC+).
“As stated, a DPC demo's goals would also be the same as, or similar to, the MSSP,” wrote Penso in the RFI response. “That is, enhance or improve beneficiary access, reduce administrative burden, and create a better provider revenue stream.”
“The providers serving more than 10 million Medicare beneficiaries in the MSSP are invested in the ACO model and recognize there are flaws in the program that need to be addressed,” continued Penso. “Financial benchmarking, risk adjustment, and quality measurement still need improvement. Reforms should be made in the context of existing programs, rather than a new, rather redundant model.”
Along these lines, AMGA suggested the advancements in care delivery and payment envisioned in a DPC model could likewise be tested in MSSP or the CPC+ demonstration.
Specifically, AMGA stated CMS could test innovations — including fixed beneficiary payments per month and modifications to claims submission processes — through MSSP and ACO demonstrations.
AMGA also expressed concern that proposing a DPC demonstration could have a negative effect on MSSP.
“A DPC demo poses lost opportunity costs to the ACO program,” explained Penso. “Fielding a similar primary care demonstration will likely, if not undoubtedly, reduce the number of assignable MSSP beneficiaries as well as the number of beneficiaries who voluntary attest to participate in an ACO. It also runs the risk of dampening provider interest in the MSSP.”
Ultimately, AMGA stated that MSSP needs to be reformed regardless of whether CMS launches a new DPC model.
“While certainly not the focus of this RFI, there are several recognized improvements that need to be made to improve MSSP provider participation and performance success,” stated Penso.
AMGA said MSSP is in need of refinements and improvements in several areas including financial benchmarks, risk adjustment, quality performance measurement, beneficiary incentives, and payment waivers.
As part of AMGA’s RFI response, the group submitted additional comments addressing potential problems that could arise if CMS chose to launch a DPC model rather than improve MSSP and ACOs.
“In our experience the administrative and clinical competencies CMS requires in order to participate in a CMMI demonstration likely far exceed those currently participating in commercial direct provider contracts or other small and/or independent providers who have to date held an interest in the model,” concluded Penso.