Leading consumer groups, led by the Campaign for Better Care (CBC), today filed comments urging the Centers for Medicare and Medicaid Services (CMS) to prioritize ensuring that accountable care organizations (ACOs) participating in the next cycle of the Medicare Shared Savings Program (MSSP) deliver high-quality, high-value care that enhances coordination of care, supports beneficiary choice and empowerment, and improves ready access to health services. The CBC is led by the National Partnership for Women & Families; among its members are Community Catalyst, the National Health Law Program and the American Cancer Society Cancer Action Network.

“ACOs are a promising approach to improving the quality, experience and cost of care because they align payment with value and quality and encourage health care providers to deliver better coordinated care,” said Debra L. Ness, president of the National Partnership. “But they will only achieve their potential if they truly put patients and family caregivers at the center of care delivery. This requires partnering with patients and families at every level: in care design, in policy and governance, and at the community level. The next generation of MSSP ACOs can help meet the historic goals and timetables the Obama administration recently laid out for Medicare payment and delivery system reform. Implementing this vision for smarter spending, better care, and healthier outcomes, however, will require partnering with patients as co-creators not only of their own health, but of the health care delivery system as well. The CBC’s recommendations for the Medicare Shared Savings Program can help ACOs do much more to support Medicare beneficiaries and their family caregivers going forward.”

The CBC comments address ACO governance, beneficiary assignment, beneficiary notification and data sharing, eligibility requirements for MSSP ACOs, regulatory waivers, and additional program requirements and beneficiary protections, such as grievance and appeals processes.

The comment letter notes that the most successful ACOs will be grounded in comprehensive and well-coordinated primary care — a true patient-centered medical home — and that these core elements must be a driving force in the next cycle of the Medicare Shared Savings Program.

CMS’ priority for the MSSP must be to ensure that all participating ACOs deliver high quality, well-coordinated care to beneficiaries, the letter says. CMS must hold all participating ACOs accountable for changing care delivery to achieve these goals. Accordingly, the next evolution of MSSP must ensure that changes to the ACO financial model are accompanied by strong accountability mechanisms.

The comment letter urges that participating ACOs be held to a high standard with respect to quality performance. Quality measures applied to MSSP ACOs should focus on coordination of care, including transitions of care, hospital admissions and readmissions, use of emergency departments, and medication management. CMS should prioritize the use of patient experience and patient-reported outcomes measures.

“We strongly support requiring consumer/beneficiary involvement in ACO governance,” it says. “Patient and family representatives bring unique perspectives that can help ACOs to achieve the goals of quality improvement and cost reduction. Bringing such insights to light, however, requires engaging patient ad family representatives in meaningful ways.” The letter urges CMS to require ACOs to describe in their applications an orientation and onboarding process for consumer/beneficiary representatives on governance boards.

The letter says the groups strongly support CMS’ proposal to require MSSP ACOs to describe how they will promote use of health IT to improve care coordination, including plans to partner with long-term and post-acute care providers, and to identify performance targets for assessing progress.

The Campaign for Better Care’s comment letter is available here.