Aledade’s Annual Hill Day Puts Spotlight on Growing Support for Primary Care and Accountable Care

Physicians and FQHC Leaders Advocated on behalf of Physician-led ACOs during annual event

The Aledade Policy team met with several U.S. lawmakers on Capitol Hill last week to advocate on behalf of our physician-led Accountable Care Organizations (ACOs). Accompanying our Policy team were four of our member physicians and two leaders with federally qualified health centers (FQHCs). We also were joined by the National Association of Accountable Care Organizations (NAACOS), and others in the ACO community, to advocate for primary care and accountable care with legislators. We held meetings with both Democrats and Republicans, and lawmakers in both the U.S. Senate and the U.S. House of Representatives.

During the meetings, we shared the unique needs of independent practices and FQHCs face, such as how their participation in an ACO is vital for them to deliver high quality care to their patients and communities. The physicians and FQHC leaders spoke about how shared savings has enabled them to hire more staff, invest in extended hours to keep patients out of the emergency department and expand outreach programs to continually reach patients who have chronic conditions. These benefits result in reduced hospitalization and emergency department visits and improved patient outcomes.

Our short term priorities include advocating for Congress to extend the financial incentives to join Alternative Payment Models (APMs), which the Value in Health Care Act (S.3503/H.R. 5013) would do in several ways. These include extending the APM incentives for two years and freezing qualifying thresholds; ensuring APM benchmarks do not penalize clinicians for prior success; increasing flexibility for clinicians in ACOs; and removing regulatory burden.

In particular, we asked the lawmakers to work with CMS to extend the Web Interface quality reporting. We also asked them to exempt clinicians in APMs from the Merit Based Incentive Program (MIPs) reporting that promotes the interoperability category. As in previous years, Congress is expected to address the 2.8% cut to the Medicare Physician Fee Schedule in an end-of-year package. However, as we enter 2025, we recognize the need to make long-term reforms to both physician payments and the Medicare Access and CHIP Reauthorization Act (MACRA).

Aledade responds to CMS on several issues impacting physician-led ACOs

Last week Aledade also submitted our comments to CMS in response to the 2025 Proposed Physician Fee Schedule (PFS). We are grateful to CMS for their continued efforts to refine and improve MSSP.

We shared the following recommendations:

• We urged CMS to maintain accurate quality reporting through the web-faced interface for ACOs as the agency advances the health information exchange. We also strongly recommended that CMS shift its file format for electronic Quality Measures from QRDA-I to QRDA-III.
• We voiced support for the introduction of the Health Equity Benchmark Adjustment (HEBA) but urged CMS to go further in proposals so more ACOs can benefit from serving high risk and complex patient populations.
• While we commended CMS for the proposal to make Prepaid Shared Savings available, we asked for more flexibility in reporting and use of those funds, since Shared Savings do not have these restrictions. We also recommended that CMS remove requirements for rebasing and the requirement to start a new contract.
• As CMS carefully thinks through strategies to offer a higher risk track in MSSP, we cautioned against replacing the current Enhanced track. We suggested an easier way to prevent a loss of Medicare savings due to ACO selection. We also articulated the benefits a higher savings rate could have on future innovation in ACOs.

Outside of MSSP, we also did the following:

• Expressed our appreciation for CMS' proposals to support advanced primary care delivery.
• Thanked CMS for its willingness to address care management services gaps in billing code utilization and payment.
• Provided feedback on ways to reduce administrative burden for participating practices.
• Voiced our appreciation of CMS' continued efforts to use regulatory levers to bolster support for equitable access to comprehensive primary care.
• Commended CMS for using its available authority to support critical flexibilities that remain in place through 2025.

In actuality, Congress is expected to extend the telehealth flexibilities from the Public Health Emergency for two additional years. We went a step further and asked CMS to consider making these policies permanent.

Advocacy Outlook for the Remainder of 2024

We expect the upcoming presidential election to consume a lot of policy space and news in the final weeks of 2024. In addition, Congress has some pressing tasks. These include addressing physician payment cuts and passing fiscal year federal spending legislation to avoid a government shutdown in October. For CMS, we expect the final PFS to be published in early November.

As always, we will continue to keep you informed and up-to-date on issues related to primary care and accountable care policy.

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