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April 26, 2016 Patrick Conway, MD Dear Deputy Administrator Conway, We, the undersigned, strongly support CMS' drive towards value-based care, and your leadership in developing models within CMMI that support this goal. We have participated in value-based Medicare models such as the Next Generation ACO, Pioneer ACO, the Medicare Shared Savings Program ACO, the Physician Group Practice Demonstration and the Bundled Payment for Care Improvement models. We would like to bring to your attention a matter of critical importance to all of us: the current ACO/BPCI overlap policy that has the potential to tum delivery systems away from the ACO models - and particularly the most advanced Next Generation ACO model -- and reverse gains CMS has made toward its laudable goal of having 50% of Medicare payments in an alternative payment model by 2018. Under current policy, we believe that funds flow between the two models can negatively impact ACOs - particularly high performing ACOs -- to such a degree that it could make it difficult, if not impossible, for these ACOs to realize any shared savings. This will likely force high-performing ACOs and other low cost ACOs to withdraw from the ACO models, particularly the models with downside financial risk. CMS has a stated goal of supporting value-based payment models that link accountability for cost, quality and experience of care. The ACO models promote value at the highest level, with accountability for population cost, quality and experience over multiple years. The CMS ACO models were designed to hold ACOs accountable for the total cost of care of the Medicare beneficiaries aligned to them, regardless of where care is "initiated." However, the current overlap policy removes from ACO accountability the cost of care during a BPCI episode, while still holding the ACO accountable for patient experience and quality, de-linking the components of the three-part aim. We support CMS' approach to testing and evolving multiple approaches to deliver value, including BPCI models. However, we would strongly encourage you to look quickly into alternative approaches to the current overlap policy so that both ACO and BPCI models can thrive, and CMS can achieve its goals for the growth of alternative payment models. The current policy defaults to the benefit of bundled participants where other policy choices are possible. An alternative to the current overlap policy, that does not subject ACOs to BPCI target pricing, is particularly important now to support continued participation in ACO models. Should you have any questions, please contact Emily Brower from Atrius Health at 617.559.8567 or at [email protected]. Thank you for your timely attention to this matter. Sincerely, ABS Managed Care Administrators, Inc. Accountable Care Options, LLC Aledade, Inc. cc: |