Internists Submit Letter to Improve Quality of Care in Reactionto Proposed CMS Rule on Medicare Shared Savings Program

Coalition letter to CMS proposes recommendations to improve alternative to "fee-for-service"

February 6, 2015

(Washington)-The American College of Physicians (ACP) today joined 16 other health care organizations in submitting a letter to the Centers for Medicare and Medicaid Services (CMS) recommending improvements to fee-for-service (FFS) payment. The 35-page letter addresses a proposed CMS rule on the Medicare Shared Savings Program (MSSP).

MSSP was established to facilitate coordination and cooperation among providers to improve the quality of care for Medicare Fee-For-Service (FFS) beneficiaries and reduce unnecessary costs. Eligible providers, hospitals, and suppliers participate in the Shared Savings Program by creating or participating in an Accountable Care Organization (ACO) that is responsible for the quality and cost of care provided to a defined population

There are now more than 400 ACOs participating in the program, covering about 7.2 million Medicare beneficiaries.

"The MSSP structure allows committed physicians and other healthcare professionals to join and take accountability for the provision of effective, efficient care that is sensitive to the needs of their patient population," said ACP President David A. Fleming, MD, MA, MACP. "The recommendations made in this joint comment letter serve to ensure the continued health and general viability of this important component of the Medicare program."

The detailed letter builds on proposed efforts of CMS to improve the program, and highlights and expands upon changes that would make participation of physicians and other healthcare providers within the MSSP more desirable. The recommendations encourage CMS to better recognize the significant financial and resource commitment required for participation and provide increased flexibility and choice to facilitate participation in a manner that best fits the specific characteristics of the ACOs.

Recommendations within the comment letter specifically address improvements in beneficiary attribution; structures that allow participating ACOs adequate time to develop the infrastructure and skills necessary for successful program participation; incentives provided to recognize improvements both in quality and cost efficiency; and methodology to establish both cost and quality benchmarks.

"These MSSPs represent an alternative to the current volume-oriented Medicare "Fee-for Service" payment model -- one that promotes more value-oriented care, noted ACP's Coding and Payment Subcommittee chair Doug Leahy, MD, MACP. "It is a program that should be supported and nurtured, and the recommendations in this letter serve as a road map toward this goal."

Signatories to the letter include:

AMDA - The Society for Post-Acute and Long-Term Care Medicine
American Academy of Allergy, Asthma & Immunology
American Academy of Family Physicians
American Academy of Home Care Medicine
American College of Osteopathic Internists
American College of Physicians
American Medical Association
American Medical Group Association
American Psychiatric Association
Association of American Medical Colleges
Collaborative Health Systems, a subsidiary of Universal American
Heart Rhythm Society
Medical Group Management Association
National Coalition on Health Care
Premier healthcare alliance
Society of General Internal Medicine
Trinity Health


The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 141,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter and Facebook.

Contact: David Kinsman, (202) 261-4554