AMGA, formerly American Medical Group Association, this week submitted comments on CMS' proposed new mandatory bundled payment program for heart attacks and bypass surgeries.
The comments were submitted via a letter to CMS Acting Administrator Andy Slavitt.
Here are five things to know from that letter.
1. AMGA believes CMS should allow accountable care organizations to take the lead or own episode payment model arrangements. "The key to succeeding in episode-based payments is care integration and coordination," AMGA President and CEO Donald W. Fisher, PhD, said in a statement. "AMGA members are very experienced in these areas, and we therefore think ACOs should have the opportunity to take the lead in these bundled payment arrangements for their assigned beneficiaries."
2. AMGA does not object to CMS' proposal to exclude metropolitan statistical areas based on acute myocardial infarction episode criteria only.
3. AMGA agrees with CMS provisions in regard to when an episode payment model episode would be canceled. CMS proposes to cancel an EPM episode when the beneficiary dies during the anchor hospitalization, according to AMGA. The group said CMS would also cancel an EPM episode when the beneficiary initiates any Bundled Payment for Care Improvement model episode.
4. AMGA generally agrees with CMS' method of setting EPM episode prices and paying EPM participants. However, the group recommends CMS reconsider its proposal to update target prices every performance year using previous years' historical data "as this creates the same problem ACOs faced in having to continuously improve upon historical performance," said AMGA. "Based on our members' ACO program experience, we've recommended that CMS reconsider how the agency proposes to update episode target prices through the five-year demo period. We want to avoid a situation in which successful performance is not compromised by requiring providers to continually improve upon historical performance," Dr. Fisher said.
5. AMGA did, however, express concerns about CMS' continuing approach to risk setting. CMS is again proposing to not make risk adjustments based on beneficiary specific demographic characteristics or clinical indicators. "Risk adjustment also is a crucial aspect of any bundled or episode-based model of care, particularly as the demonstration evolves to fully regional pricing. There are state examples that use beneficiary demographics to more accurately risk-adjust in their bundled payment initiatives and we believe that CMS can learn from these examples," Dr. Fisher said.