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Comment Letter | Medicare Payment and Reimbursement

HFMA Comments on CMS's Proposed Changes to the Medicare Shared Savings Program

Comment Letter | Medicare Payment and Reimbursement

HFMA Comments on CMS's Proposed Changes to the Medicare Shared Savings Program

HFMA submitted a comment letter to CMS on the proposed changes to the Medicare Shared Savings Program (MSSP) benchmarking and trending methodologies published in the February 3, 2016, Federal Register.

HFMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed changes to the Medicare Shared Savings Program (MSSP) benchmarking and trending methodologies published in the February 3, 2016, Federal Register.

Regarding the specific proposals included in the rule, HFMA commented on the following:
 

  • Definition of assignable beneficiaries
  • Transition to regional data for setting benchmarks
  • Risk adjustment methodology for continuously assigned beneficiaries
  • Calculating regional average expenditures using state-level ESRD data
  • Reversal of decision to add savings achieved in prior periods back to the historical benchmark
  • Determination reopening criteria
  • Inducements to facilitate transition to two-sided risk bearing models

Download the comment letter 

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