In a May 11th letter to CMS Administrator, Dr. Don Berwick, the American Medical Group Association (AMGA) President, Don Fisher, complained that the draft regs for the Medicare Shared Savings Programs were “overly prescriptive, operationally burdensome, and the incentives are too difficult to achieve to make this voluntary program attractive.” In particular, Fisher mentioned concerns raised by AMGA members regarding:
- Risk sharing requirements
- Static risk adjustment
- Retrospective attribution
- Quality measurement requirements
- Minimum Savings requirements
He reminded Dr. Berwick that most policy experts believe “multi-specialty medical groups are best poised to become ACOs in the short term.” But he warned that, in a survey of AMGA members, 93 percent said they would not enroll as an ACO under the current regulatory framework.
Mr. Fisher worries that CMS may not be willing to make sufficiently substantial changes in the regs at this point, that providers will not voluntarily participate in large numbers, and that the federal government response will be across the board “draconian” cuts.
I share Fisher’s worries. But, I choose to be optimistic that CMS can show some real agility and re-work the regulations to regain the momentum they had just a few months ago.