(ACO) regulations - American Society of Anesthesiologists

CMS-1345-P 250
chances of demonstrating savings and receiving a shared savings payment would
improve. Behaviors such as these could allow an ACO to achieve apparent savings by
coding changes alone and without improved methods of beneficiary care.
We have made adjustments to account for the upward trend in risk scores in other
programs. For example, for the MA program we make adjustments to account for the
upward trend in FFS diagnostic coding and CMS-HCC model changes through
normalization factors and coding intensity adjustments. Another approach to addressing
this upward trend in diagnostic coding would be to incorporate an annual cap in the
amount of risk score growth we would allow for each ACO. One option for setting the
annual cap could be setting a fixed growth percentage for all ACOs, and any increase in
risk score growth above the cap would be negated. A challenge to this approach would
be determining a generally acceptable sized cap. A second option would be to establish a
risk score for the ACO's assigned population during the agreement period based on the
calculated risk score of beneficiaries who were used to calculate the ACO's benchmark
This would establish an annual cap, that is based on experience specific to each
individual ACO and would thus result in an individually calculated cap for each ACO.
Yet another alternative we considered for addressing the upward trend in coding intensity
would be to use a methodology similar to the MA methodology that would reduce the
amount of growth in the risk scores for beneficiaries assigned to the ACOs, but continue
to allow increases. However, modeling this approach showed that it would reward those
organizations with exceptionally high risk score growth while penalizing organizations
that do not engage in efforts to more completely and accurately code since their risk score
growth could go negative if they did not code sufficiently intensively.