Premier Statement on the Medicare Shared Savings Program Provisions Included in the CY 2019 Physician Fee Schedule Final Rule

By Blair Childs, senior vice president of public affairs, Premier

Premier is encouraged that CMS has finalized a voluntary six-month extension for existing ACOs participating in the Medicare Shared Savings Program (MSSP). This will afford them sufficient time to prepare for extending their agreements while CMS works on finalizing other program changes. We’re concerned, however, that if an ACO extends its agreement period and changes its participant list between the six-month extension and the start of the new model, the ACO’s aligned beneficiaries could be significantly different for the two performance periods. This would make an ACO accountable for the quality and financial performance of some of its assigned beneficiaries with little opportunity to manage these beneficiaries’ care. We encourage CMS to use a singular assignment window for the two six-month performance periods in 2019 or take other mitigating steps.

Premier provided extensive comments to CMS on its proposed redesign of the MSSP based on learnings from ACOs in our Population Health Management Collaborative. We hope that the final rule implementing the remaining provisions will reflect this feedback.