Opportunities for Improvement in the Medicare Shared Savings Program
On Friday, February 6th, the Telecommunications Industry Association (TIA) sent comments (and separately joined a diverse group of industry stakeholders in a letter) urging the Department of Health and Human Services’ (HHS) Centers for Medicare and Medicaid Services (CMS) to make much needed changes to the Medicare Shared Savings Plan (MSSP) to help fully realize the potential of telehealth and remote patient monitoring (RPM) products and services.
These are important steps in advocating on long-held ICT industry views that medical practitioners should be fairly and adequately compensated for their use of advanced telehealth and RPM solutions.
As background, the Medicare Shared Savings Program was created under the Affordable Care Act to help facilitate the coordination and cooperation of health care providers participating in an Accountable Care Organization (ACO), a group of health care providers working together to improve the delivery and quality of care, with payment and reimbursement tied to quality measures and cost reductions. Under this program, participating ACOs would agree to have reimbursement for services tied to quality measures and reductions in the cost of care, by sharing in the savings and in taking on associated risks. This is in contrast the traditional fee-for-service model, where individual services are paid for separately.
Both TIA’s comments and the multistakeholder letter argue that the known and demonstrated benefits of these innovative products and services are being prevented by onerous and outdated regulations, and that CMS can take tangible steps in the short-term to help address these issues. While applauding CMS’s commitment to looking at ways of integrating innovations in health information and communications technology (ICT) in the delivery of health care, we urged for greater flexibility for ACOs participating in the MSSP to utilize these innovative solutions to help improve care and lower costs.
Back in June of 2014, TIA joined 11 other organizations in a letter urging HHS Secretary Burwell to waive certain restriction on the use of telehealth (specifically those found in Section 1834[m] of the Social Security Act), and also request public comment in the forthcoming rule proposal on how telemedicine and remote monitoring could be further utilized by ACOs to meeting the goals of the MSSP: improving quality of care and reducing costs.
Upon release of the MSSP rule proposal in December of 2014, we were happy to see CMS request public comment on the use of telemedicine by ACOs. In the proposed rule, CMS acknowledged that the use of remote access technologies can be beneficial, and that waivers of certain restrictions may encourage broader use of telehealth. However, the waivers CMS proposed do not go nearly far enough to make a real impact for ACOs and the patients who would benefit most from telehealth and remote monitoring services.
In response, TIA and a diverse set of partners in the healthcare space worked to draft consensus comments to help CMS understand the importance of how the MSSP can be used to realize the full potential of telehealth and RPM, and how CMS can lead. Specifically, TIA and the other organizations had two key recommendations:
- First, we argued that CMS should waive 1834(m) restriction on telehealth in order to allow ACOs the needed flexibility to be as effective and efficient as possible. Such a waiver would reflect the established and growing body of evidence supporting the benefits of telehealth. If there had to be certain conditions applied to the waiver, we recommended that waivers to be granted to some ACOs and allow the rest to apply for a waiver.
- Secondly, we urged the Secretary of HHS to authorize the unbundled payment for remote monitoring for all ACOs participating in the MSSP. Current reimbursement for RPM is contingent upon being bundled with another service, thus preventing remote monitoring from being fully utilized. Additionally, we urged CMS to continue their practice of not including remote patient monitoring under the definition of “telehealth”, thus exempting it from 1834(m) restrictions.
TIA believes that CMS acting consistent with these views would not only support the wider use of telehealth and remote patient monitoring for ACOs, but will be a springboard for greater adoption and utilization across the healthcare system. We look forward to seeing how the comments from TIA and other industry stakeholders will be received by CMS, and to working with them moving forward to improve the American healthcare system through the enhanced use of telehealth and RPM.