Op-Ed

Comments on the Proposed Rulemaking for the Medicare Shared Savings Program

The Engelberg Center and the Dartmouth Institute for Health Policy & Clinical Practice submitted comments to the Centers for Medicare & Medicaid Services on the Medicare Shared Savings Program Notice for Proposed Rulemaking (NPRM) and on the waiver designs in connection with the Medicare Shared Savings Program and the Innovation Center.

The Engelberg Center and the Dartmouth Institute have long advocated for the development of new payment models – including the concept of accountable care organizations (ACOs) – in order to support provider efforts to deliver better care to patients. As when we first advocated for a Medicare ACO program several years ago, the goal remains a simple one: to help physicians, hospitals, and other health care providers – whether in the public sector or private sector – deliver high-value care by providing support to allow them to work together to improve quality while lowering costs. Currently, many steps that improve care and lower overall costs are reimbursed either poorly or not at all by Medicare, making it difficult for providers to sustain steps to improve their delivery of care.

The path toward implementing accountable care will not be easy for health care organizations or Medicare, Medicaid, and private payers. The transition toward integrated, coordinated and accountable care requires investments in health information technology that supports measurement for both improvement and accountability; the development of care management programs that allow teams comprised of nurses, pharmacists and other health professionals to deliver the right care to the right patient and maintain health while preventing costly complications of chronic diseases; the effective coordination of care – especially for the frail elderly or for those with multiple chronic conditions – across clinicians and sites of care; and governance and leadership structures that can strategically deploy the resources and project management required to implement these new models of care. These activities take considerable time, effort, and money. In addition, the steps must be implemented in a way that, over time, achieves reductions in health care costs. Thus, effective payment reforms must provide both new financial support for effective investments to improve care, and lead to evidence of meaningful cost savings and quality improvement. Further, these efforts must occur in a way that promotes beneficiary involvement. Though these changes are not easy, the ACO program and related – hopefully reinforcing – Medicare payment reforms are essential for supporting needed steps by providers to continue to improve care.

Read the full comments on proposed rulemaking for the Medicare Shared Savings Program

Read the full comments on the waiver designs in connection with the Medicare Shared Savings Program and the Innovation Center