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FAH Statement | CMMI | Medicare | FAH Policy Blog Team

FAH Comments on Medicare’s Extreme & Uncontrollable Circumstances Policies

FAH sent a letter today to CMS Administrator Seema Verma outlining ways that the Medicare Shared Savings Program’s Extreme and Uncontrollable Circumstances Policies interim final rule could be improved.

The letter expressed appreciation for CMS’ recognition of the need for such a policy and relief it provides to Accountable Care Organizations (ACOs) affected by this year’s disasters, including the devastating hurricanes.

However, FAH points out that there is room for improvement:

“We believe the policy could be improved if CMS would incorporate a process for further mitigating shared losses for ACOs participating in a performance-based risk track beyond the mitigation proposed in the interim final rule. Specifically, we believe that losses should be waived, or a modifier used to adjust, for ACOs suffering losses beyond those recognized in the proposed methodology.”

You can read the letter here.