Accountable care organizations (ACOs) should play a major role for the cardiac care bundled payments model that the Centers for Medicare & Medicaid Services (CMS) proposed in July, according to the American Group Medical Association (AMGA).

The AMGA submitted the comments on Oct. 3 in a letter addressed to CMS acting administrator Andy Slavitt.

Under the cardiac care bundled payments model, which is scheduled to begin in July of next year, CMS will randomly select hospitals in 98 metropolitan areas to participate. There is no application process.

CMS proposes to update target prices every year using previous years’ historical data, but the AMGA recommends that the agency adopts trending forward the initial three year historical data for the five years of the demonstration project. The AMGA said that ACOs have had troubles trying to improve upon their historical performance.

The AMGA is also concerned that CMS proposes to not make risk adjustments based on beneficiary specific demographic characteristics or clinical indicators. The AMGA said that CMS should review risk adjustments that the states of Arkansas, Ohio and Tennessee have implemented in their multi-payor bundled payment programs for lower extremity joint replacement surgeries.

In addition, the AMGA said that CMS should not exclude any ACOs from participating in the cardiac care bundled payments model and should allow ACOs the option to participate as an entity that bears financial risk.

“The key to succeeding in episode-based payments is care integration and coordination,” AMGA president and CEO Donald W. Fisher, PhD, said in a news release. “Based on our members’ ACO program experience, we’ve recommended that CMS reconsider how the agency proposes to update episode target prices through the five-year demo period. We want to avoid a situation in which successful performance is not compromised by requiring providers to continually improve upon historical performance.”