LMI’s Merrill Harmison on Health Equity and Accountable Care Organizations

Could you share more about your and your team’s work on the Medicare Shared Savings Program?

• We provide strategic support to CMS to facilitate the implementation of the Medicare Shared Savings Program. This consists of overseeing and reviewing applications submitted by prospective Accountable Care Organizations (ACOs) and conducting ongoing monitoring and compliance checks for ACOs participating in the program. We also report on key trends for CMS leadership and public distribution, assist ACOs by managing inquiries, develop new policies, and refine existing regulation through the rulemaking process. Through our work with CMS and other contractors on the project, we’re able to make sure that the program stays up and running and continues to garner success for the ACOs that participate, the Medicare beneficiaries served by those ACOs, and the integrity of the Medicare Trust Fund.

How does LMI’s expertise help CMS achieve their goal of “having all people with Traditional Medicare enrollees in an accountable care relationship with their health care provider by 2030?”

• We put significant effort into the application process to ensure that ACOs interested in participating in the program can complete an approved application. This includes contacting ACOs directly to inform them of upcoming deadlines and issues they may have with their applications and providing technical assistance when needed. This year, we have facilitated a series of webinar “office hours” intended to help new (and returning) ACOs with common questions associated with the application. These resources are all available on the Shared Savings Program Application Toolkit. We work closely with CMS to make sure these resources are up-to-date and helpful.

• At a broader level, we have also helped CMS write the Shared Savings Program provisions of the Medicare Physician Fee Schedule (MPFS) Proposed and Final rules and looked for opportunities to use policy channels to increase participation. We specifically focused on opportunities to engage potential ACOs serving Medicare beneficiaries in rural areas, underserved areas, and racial/ethnic minority groups, all of which have not had the same access to ACOs. Last year, with the CY 2023 MPFS, we worked with CMS to draft a new payment option, know as Advance Investment Payments (AIP), designed to help healthcare providers in rural and underserved areas form new ACOs and achieve success in the Shared Savings Program. Since the finalization of that policy, we have worked with CMS subject matter experts to implement AIP for the 2024 application cycle, and have seen a number of new applicants interested in this option.

How is LMI helping healthcare transition to a value over volume system?

• The Shared Savings Program is one of the largest value-based purchasing programs in the country, and serves nearly 11 million Medicare beneficiaries as of January 2023. In performance year 2021, the program resulted in a total earned shared savings of $2 billion. With support from the current administration and CMS leadership, there is a great opportunity for the Shared Savings Program to continue to grow and generate further savings for Medicare. The success of the program also has the opportunity to provide a learning opportunity for other Center for Medicare and Medicaid Innovation models, as well as value-based care arrangements in Medicare Advantage, Medicaid, and even private payers. LMI’s continued support for this program and our work in other value-based care areas will help transform volume-based healthcare into high-quality and cost-efficient care. By realigning financial incentives through programs and policies like the Shared Savings Program, we can ensure that healthcare providers are encouraged to generate savings by delivering high-quality care.

Are you and your team finding that the push toward ACOs is helping bridge disparities in healthcare in certain populations? How so?

• Absolutely. One of the top priorities for the administration and CMS is finding ways to close disparities in care and promote health equity among disenfranchised communities and racial/ethnic minority groups. The population-based approach of the Shared Savings Program provides an opportunity for ACOs to work to improve the quality of care delivered to the beneficiaries they serve in their community. And by introducing and implementing new policies, like AIP and other rulemaking provisions, we can specifically address inequality in the healthcare received by underserved Medicare beneficiaries and work to bridge the gap and end disparities.