As the industry transitions from the fee-for-service model to value-based care, many providers are finding themselves struggling to straddle the divide. The shift away from volume has created many new administrative burdens that are handicapping providers’ ability to focus on patient care.
In an effort to alleviate these significant provider burdens, CMS recently sent out a request for information to various organizations—including the American Medical Group Association (AMGA) and Medical Group Management Association (MGMA)—on how they can better streamline the process.
AMGA proposed several reforms, saying in a statement that “[We have] recommended that [CMS] reform a number of regulations and policies to ensure they support providers’ ability to deliver care in value-based model … [including] detailed policy recommendations designed to reduce Medicare programs’ regulatory complexity so our member providers are better able to focus on providing the best possible patient care.”
The recommendations from the AMGA and MGMA include:
1. Synchronize rules and regulations across programs.
Differing rules and regulations across risk-based and non-risk models create extra complications for providers. Within the Medicare Shared Savings Program (MSSP) the rules currently governing the accountable care organizations (ACOs) shift based on the ACO’s accepted amount of financial risk. Waivers are restricted based on this level of risk.
However, the AMGA believes this is counterproductive and should change, and that even non-risk based ACOs should be allowed to deliver coordinated care using the appropriate waivers. The organization stated in their comment letter that “providers that participate in these value-based arrangements should enjoy a consistent regulatory framework and have access to the tools that support their ability to deliver the highest quality care to their patients. The only meaningful difference among the levels of the MSSP’s glide path should be the level of financial risk an ACO faces as it progresses.”
AMGA also commented that the regulations developed in the fee-for-service model don’t account for the investment that providers must make to transition to value-based care and population health models. “Limiting waivers and beneficiary incentive opportunities to a subset of ACOs creates a situation to adjust how they deliver care with no benefit to patients,” the letter concludes.
2. Simplify quality measurement reporting.
An overly-complex system for quality reporting in value-based care models is a huge burden for providers, requiring excessive amounts of time and manpower, as well as complex IT infrastructures—which leads to increased costs.
AMGA suggested CMS scale down the amount of quality measures for value-based care providers. “Using a standard set of value measures will help reduce the variation in the measures that are reported and help eliminate unnecessary confusion and administrative burdens,” AMGA wrote in their comment letter to CMS. AMGA suggested that CMS use a set of 14 process and outcomes quality measures approved in 2018 by the association’s Board of Directors.