AMGA Statement on Medicare Shared Savings Program Changes in the FY 2022 Inpatient Prospective Payment System Proposed Rule

Alexandria, VA – AMGA today recommended that the Centers for Medicare & Medicaid Services (CMS) finalize its proposal to let accountable care organizations (ACOs) in the Medicare Shared Savings Program (MSSP) opt to remain at their current level within the BASIC glide path for an additional performance year. However, AMGA opposes the requirement that ACOs deferring advancement skip a level in the glide path. An ACO that opts to halt its advancement because of the COVID-19 pandemic would jump ahead (i.e. Level A ACOs would move to Level C or Level D) but would not have the experience necessary to succeed in a level with higher risk.

 “CMS created a glide path to taking on risk for a reason,” said AMGA President and CEO Jerry Penso, M.D., M.B.A. “While we appreciate the flexibility CMS is offering ACOs due to the COVID-19 pandemic, we believe that ensuring ACOs can learn to take on risk more gradually is important for the move to value to succeed.”

The effect of finalizing this “skip” policy could see an ACO abruptly and prematurely shift from a one-sided arrangement (i.e., Level A) to a more advanced two-sided risk arrangement (i.e., Level D). AMGA believes that a smoother transition to risk is essential to ensure the success of MSSP ACOs.

AMGA’s full comments are available here.


About AMGA
 AMGA is a trade association leading the transformation of health care in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high-quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans.


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