NAACOS to CMS: Bring Innovations From Other APMs to MSSP

Why It Matters

Implementing these reforms could boost ACO cash flow, enhance care coordination, and preserve participation in the permanent MSSP, strengthening Medicare’s value‑based care agenda.

Key Takeaways

• Capitation could provide steady cash flow for ACOs
• Voluntary alignment boosts beneficiary alignment up to twentyfold
• eCQMs face interoperability hurdles, slowing digital reporting
• Benchmark ratchet penalizes ACOs after contract renewals
• ACCESS and WISeR models offer tech payment and fraud tools

Pulse Analysis

The MSSP has long been the cornerstone of Medicare’s permanent value‑based payment landscape, yet its innovation pipeline has stalled since the 2019 Pathways to Success rule. By borrowing proven mechanisms from newer models—such as the capitation structures used in Next Gen and REACH—CMS could give ACOs predictable revenue streams, reducing the year‑and‑a‑half lag in shared‑savings payouts that hampers investment in care transformation. Steady cash flow is especially critical for primary‑care practices that struggled with pandemic‑induced financial volatility.

A second lever highlighted by NAACOS is voluntary alignment, which in the REACH model produced nearly twenty‑fold higher beneficiary alignment. This approach mitigates churn among healthier patients and new‑to‑Medicare enrollees, expanding the risk pool without imposing additional administrative burdens. Coupled with streamlined quality reporting—shifting from cumbersome manual submissions to interoperable electronic clinical quality measures—ACO teams can align clinical improvement efforts directly with reporting requirements, eliminating duplicate work and accelerating performance.

Finally, addressing systemic disincentives like the benchmark ratchet is essential to retain ACO participation. The ratchet lowers future benchmarks after each contract renewal, effectively penalizing past successes and prompting some ACOs to exit MSSP for alternative models. NAACOS proposes higher shared‑savings add‑backs and tighter guardrails on prospective trend calculations, while also integrating elements from the ACCESS and WISeR pilots to fund technology adoption and empower ACOs in fraud detection. Together, these reforms could revitalize MSSP, ensuring it remains a viable, innovative pathway for Medicare’s shift toward value‑based care.