Proposed Benchmarking Updates to the Medicare Shared Savings Program

On July 7, 2022, the Center for Medicare and Medicaid Services (CMS) released the 2023 Medicare Physician Fee Schedule Proposed Rule which contained some of the larger proposed updates to the Medicare Shared Savings Program (MSSP) in the history of the program. While not yet final, many of these proposed changes have been received favorably by the industry, providing an early indication that several of the updates may become final. With the final rule set to come out later this year, this white paper contains a deep dive, including detailed examples, of the proposed updates to the MSSP benchmarking and risk adjustment methodologies set forth in CMS's proposal. We encourage both current MSSP ACOs as well as those thinking about entering or re-entering the program to review this paper as they assess the potential implications for their organization.