Download as PDF

December 2, 2020

Re: Advanced Alternative Payment Model Thresholds 

Dear Senate Majority Leader McConnell, Speaker Pelosi, Senate Minority Leader Schumer, and House Minority Leader McCarthy: 

On behalf of the 501 undersigned health care practices and accountable care organizations (ACOs), we thank you for your continued leadership during the COVID-19 public health emergency. As you know, practices taking performance-based risk in advanced alternative payment model (APM) arrangements continue to fight on the pandemic’s frontlines. We have deployed vital care coordination and management services that enhance patient care while reducing health care costs. We have taken innovative actions to advance public health in our local communities, such as scheduling telehealth visits for patients with chronic conditions; setting up drive-through COVID-19 testing centers; and helping patients access the appropriate level of care based on their symptoms. 

As Congress considers future health care legislation that will continue to bolster and advance the care delivery system, we urge you to take action to ensure that value-based care providers can continue to provide these important services by modifying the unrealistic threshold tests included in the bipartisan Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. 

To incentivize providers to switch from traditional fee-for-service Medicare to advanced APMs, MACRA provided a 5% bonus payment to qualifying participants in advanced APMs. The bonus was intended to move clinicians and practices into risk-bearing models that control costs and improve quality, and therefore, contribute to a more sustainable future for traditional Medicare. To be eligible for the bonus, an APM entity must satisfy either a revenue or a patient count threshold. The thresholds are intended to measure whether the APM entity is sufficiently increasing its participation, measured by revenue or patients, in the APM over time. In 2020, the revenue threshold is 50% and the patient count threshold is 35%. 

In 2021, both threshold tests are scheduled to increase sharply. The revenue threshold will jump to 75% and the patient participation threshold will jump to 50%. As a result, many practices who have assumed considerable financial risk and who have invested significant resources into advancing the value-based care movement will not receive their incentive payments. If providers cannot count on receiving these bonus payments, due to unrealistic thresholds, fewer providers will be willing to participate in APMs in the future, exactly the opposite of what MACRA’s authors intended when they drafted the threshold tests. This would represent an unfortunate set- back in the progress we have made in advancing the value movement and would undermine Medicare’s long-term transition to greater levels of performance-based risk. 

We ask that you recognize our commitment to advancing Medicare’s transition to value-based care by freezing the MACRA thresholds at the 2020 levels for the next two performance years (2021 and 2022). This freeze will give us the flexibility and financial security we need to continue to innovate and improve population health for our patients, as well as to continue to drive forward models that create a fiscally healthy future for the Medicare program. 

We appreciate your consideration of this matter.