AHA Statement on Proposed Medicare Shared Savings Program Rule

Tom Nickels

Executive Vice President

American Hospital Association


August 9, 2018


Hospitals and health systems have embraced the Medicare Shared Savings Program and Accountable Care Organizations (ACOs) as ways to advance their ongoing efforts to transform delivery system reform through improved care coordination and financial accountability. While we acknowledge CMS’s interest in encouraging providers to more quickly move toward accepting risk, drastically shortening the length of time in which ACOs can participate in an upside-only model ignores the reality that providers are starting at vastly different points and will have vastly different learning curves when moving toward value-based care.

The proposed rule fails to account for the fact that building a successful ACO, let alone one that is able to take on financial risk, is no small task; it requires significant investments of time, effort and finances. Hospitals and health systems must build upon their current infrastructure, which entails forming new and different contractual relationships and incentivizes successful strategies. While some have already taken significant steps toward achieving such alignment, others are not as far down this path. A more gradual pathway is critical for hospitals and health systems that are interested in participating in risk-bearing models – particularly those that are exploring such models for the first time.

For hospitals and health systems, and other providers that want to come together to provide the highest quality care for patients, the proposed rule would create barriers to entry in transitioning to value-based care. We will urge CMS to ensure that it strikes a balance between quality care for Medicare beneficiaries; savings for the Medicare program; and sufficient opportunity for ACOs to invest in the infrastructure necessary to successfully take on risk.



Arika Trim, (202) 626-2319 atrim@aha.org

Gabriella Valentine, (202) 626-2264 gdvalentine@aha.org




About the AHA

The AHA is a not-for-profit association of health care provider organizations and individuals that are committed to the health improvement of their communities. The AHA is the national advocate for its members, which include nearly 5,000 hospitals, health care systems, networks, other providers of care and 43,000 individual members. Founded in 1898, the AHA provides education for health care leaders and is a source of information on health care issues and trends. For more information, visit the AHA website at www.aha.org.