News Release
March 5, 2020 

David Pittman
NAACOS Health Policy and Communications Advisor
202-640-2689 or [email protected]  

NAACOS Recommends CMS Action to Encourage Alternative Payment Model Adoption
Letter Address Implementation Pitfalls of 2015 MACRA law 

WASHINGTON -- In a letter sent today, the National Association of ACOs (NAACOS) urged Seema Verma, administrator of the Centers for Medicare & Medicaid Services (CMS), to address several issues related to implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Improved MACRA implementation is key to spurring the adoption of alternative payment models (APMs), a priority of the Trump administration. 

Most notably, NAACOS is requesting CMS offer providers more flexibility to meet required thresholds related to Advanced APM participation, which if met rewards organizations with a 5 percent bonus on their Medicare Part B payments under the overwhelmingly bipartisan 2015 law. To earn the bonus, doctors and hospitals in Advanced APMs must either have a certain percent of Medicare payments flow through the APM or have at least a certain percentage of their Medicare patients treated under the APM. 

As required by MACRA, these thresholds increase in 2021, and many ACOs that have reached the thresholds in the past view the upcoming standards as unreachable. NAACOS has urged Congress to revise the thresholds and hopes that CMS will take action to address these thresholds in the upcoming Medicare Physician Fee Schedule, the annual regulation that sets payment policies for doctors under Medicare. CMS should also release more details on the range of where providers stand on thresholds to give ACOs a better understanding of where they and their peers stand on this important issue. This increased transparency would also help Congress understand the urgency to amend this part of MACRA.

Congress passed MACRA nearly unanimously with the goal of moving our health system to one that rewards alternative payment models like ACOs. But we risk momentum we’ve gained by taking away the big carrot – the 5 percent bonus – meant to incentivize APM participation," said Clif Gaus, Sc.D., President and CEO of NAACOS. "Congress gave CMS some flexibility in meeting the thresholds, and we’re asking CMS to exercise that freedom the greatest extent possible." 

Among other points raised in the letter, NAACOS urges CMS to: 

  • Align definitions for APM threshold calculations with those used for ACO assigned and assignable beneficiaries, which differ and create confusion for providers.
  • Allow providers that join an ACO during the first eight months of the performance year to qualify for Advanced APM bonuses if the ACO meets the QP threshold at least once that year.
    • Pay the Advanced APM bonuses by June 30 of each year, rather than waiting until the last quarter which CMS did in 2019.
    • Change the basis of the Advanced APM bonuses to be on aggregate Medicare allowed amounts, as planned in earlier regulations, rather than on the lower aggregate paid amounts which CMS used for 2019 bonuses. 
    • Reduce administrative burdens by removing the Promoting Interoperability requirements for Advanced APM ACOs.
    • Communicate clearly and publicly when significant quality measure specifications changes or interpretation take place. 

"NAACOS shares the goal of moving our system to one that better rewards value, but we must incentivize alternative payment models like ACOs and reduce regulatory burden we place on them," Gaus said. "ACOs care for a fifth of Medicare beneficiaries and nearly 500,000 physician and non-physician clinicians work in ACOs. In less than a decade, ACOs have become an integral part of our health system, so providing ACOs with the support they need is critical to moving to a value-based care system."