Health Center Regulatory Issues

Update on Medicare Rule for Health Centers

The Centers for Medicare and Medicaid Services (CMS) finalized a rule on the Medicare Shared Savings Program (MSSP) last December, bringing significant changes to the program.  Named the “Pathways to Success,” the final rule will require Accountable Care Organizations (ACOs) participating in the MSSP to take greater financial risks.  NACHC’s comments on the proposed rule focused on the following areas:

  • Health centers are important partners in accountable care arrangements, producing cost savings for the system and enhanced quality of care for beneficiaries and look forward to continuing this work together.
  •  CMS should invest in a more gradual pathway to increased levels of financial risk for provider led accountable care organizations (ACOs).
  • Many health centers, because they provide care to some of the most underserved communities in the country, require additional investment to prepare for two‐sided risk arrangements.
  • Increased flexibility in the ability to provide telehealth services will support health centers participating in the Pathways to Success Program.
  • A more appropriate benchmarking process will support participating health centers in delivering the best care for the vulnerable populations they serve.
  • CMS should be mindful of inadvertently causing “cherry‐picking” of patients by allowing ACOs to provide beneficiary incentives.

NACHC has prepared a summary of the final rule and if and how CMS responded to the issues raised in our comments. 

Health centers have been involved in a variety of MSSP ACOs since the inception.  The type of arrangements health centers have been participating in include health center only, health center led, hospital led, and provider only MSSP ACOs.  Through the years, there have been varied outcomes, but one key factor for success that health centers point to is supportive leadership.

NACHC will continue to monitor developments to the MSSP and ACOs and update health centers and PCAs of any relevant developments.

Contributors to this blog post are NACHC interns Erica Harp and Anoosha Hasan.