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News Release
December 2, 2020

NAACOS Statement on CMS Final 2021 Medicare Physician Fee Schedule
Attributed to Clif Gaus, Sc.D, President and CEO of the National Association of ACOs 

While NAACOS appreciates that the Centers for Medicare & Medicaid Services (CMS) provided some flexibility beyond what was proposed in the draft regulation, we are disappointed to see CMS move forward with sweeping changes to the way quality is assessed in the Medicare Shared Savings Program (MSSP), particularly in the midst of a pandemic. The final rule establishes new ways of measuring quality and new benchmarks for performance. In September, 10 leading healthcare organizations urged CMS not to move forward with the sweeping changes, citing, among other things, the ongoing public health emergency. In addition, the late release of this final rule gives ACOs little time to assess and prepare for such changes before the rule goes into effect. 

NAACOS urges CMS and the incoming administration to reconsider many of the ACO quality changes finalized in the 2021 Medicare Physician Fee Schedule (MPFS) rule and to work more closely with stakeholders to find appropriate solutions for streamlining ACO quality while maintaining quality as a core focus of the ACO program. We also request the agency provide safeguards for ACOs that may not be able to report 2020 quality data in early 2021 given the surges in cases of COVID-19 we are currently seeing across the country. 

ACO quality is one of several key policy areas a new Biden-Harris administration should review to improve patient care, advance Medicare’s transition to value, and lower the cost of care. NAACOS recommends the new Administration rebalance ACO incentives to attract more new ACOs to the program, while retaining existing ones. This could be accomplished by increasing shared savings rates, fixing benchmarking and risk adjustment flaws, and allowing adequate time before ACOs’ must assume risk. Additionally, we recommend CMS test and advance new accountable care concepts and models, address the troubling overlap of alternative payment models (APMs) to prioritize ACOs, and improve incentives to participate in Advanced APMs, which Congress granted in the 2015 Medicare Access and CHIP Reauthorization Act. A successful transition to value is imperative to ensure a stable and healthy Medicare program, and NAACOS looks forward to working on that with the incoming Biden-Harris administration, with the proven ACO model playing a prominent role. 


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