HIMSS Comments on the CMS 2019 MSSP Proposed Rule

In an October 16, 2018, letter, HIMSS expressed support for the Centers for Medicare & Medicaid Services (CMS) 2019 Medicare Shared Savings Program (MSSP) Proposed Regulation as well as accountable care organizations (ACOs) as an innovative care delivery model for providing and coordinating high-quality care as well as the development and use of information and technology to provide the appropriate data required by ACOs to demonstrate value while effectively managing and treating patients across the continuum of care.

HIMSS also supported extending and modifying the agreements periods from three years to five years to allow for a “gentler on ramp” for all tracks. The certainty of a five-year agreement will be more reassuring to providers for making that initial investment in becoming a program participant. However, although HIMSS appreciated CMS’s interest to move providers towards risk-based payment models, it cautioned that moving too rapidly by shortening the length of time in which ACOs can participate in an upside-only model from six years to two years may negatively affect participation in the program.

Telehealth was also a key area of consideration in the Proposed Rule. HIMSS was supportive of CMS’s proposal to expand the use of telehealth for practitioners in ACOs in performance-based risk arrangements and expanding coverage for some telehealth and telemedicine in MSSP to areas that are not designated as rural or shortage zones through limited waivers. As technology and telehealth assume an increasingly critical role in healthcare delivery, widespread inclusion in MSSP is more vital than ever to help realize its potential.

In its letter, HIMSS also emphasized that quality reporting policies should continue to strive to enhance the value proposition of participating in quality reporting programs and ensure that electronic clinical quality measures are actionable for hospitals, providers, and patients to drive improvement in care outcomes.

There was also broad support for the inclusion of beneficiary incentives in MSSP that lead to more patient engagement opportunities. HIMSS supported the MSSP Proposed Rule focus on patient engagement as an important part of motivating and encouraging more active participation by beneficiaries in their healthcare. The letter appreciated the significant flexibility granted to MSSP ACOs in the proposed rule to offer beneficiary incentives to encourage patient engagement, promote care coordination, and achieve the objectives of the Program.