ACO Proposed Rule Change: Non-Track Changes
Practical Analytic Approaches to Healthcare Challenges
On August 9th, 2018, the Centers for Medicare and Medicaid Services (CMS) announced a proposed rule change to the current Medicare Shared Savings Program (MSSP) structure. Along with updates to the tracks that are available to Accountable Care Organizations (ACOs) through the program, a number of new features and methodologies would be introduced under the new rule. These new aspects are intended to help ACOs innovate and be successful in care coordination, promote beneficiary engagement, encourage program integrity, and improve care.
The proposed rule would introduce a more rigorous benchmarking methodology for ACOs. Currently, the benchmarking methodology only incorporates regional Fee for Service (FFS) expenditure trend factors when an ACO is on their second or subsequent 3-year agreement period. Under the new rule, the regional factors will be applied to all of the agreement periods, which will become 5 years in length. Additionally, benchmarks can be adjusted in either direction up to 3% per year during an agreement period in order to reflect changes in the population’s health status.
ACOs will be given the option for each performance year whether they want prospective member assignment or preliminary prospective member assignment with a retrospective reconciliation. Currently, the methodology is determined based on the track that an ACO is enrolled in. There will also be other changes to the beneficiary assignment methodology. The definition of primary care service will be expanded, and beneficiaries may be given the option to opt in to an ACO. Additionally, voluntary alignment would continue to be allowed and allowing the member to designate any physician regardless of specialty.
Beginning January 1, 2020 ACOs would also potentially be eligible to have participating physicians receive payments for using telehealth services. Physicians of ACOs that are in a 2-sided agreement with prospective assignment would be eligible for this. Additionally, use of the SNF 3-day waiver would be expanded to apply to any ACO in a 2-sided arrangement and to critical access hospitals and small rural hospitals part of these ACOs, and 2-sided ACOs could provide incentive payments up to $20 to beneficiaries for each related primary care service they receive.
Under the proposed rule, CMS would help provide additional resources and features to help ACOs succeed. Beyond the track structure change that would occur, various aspects will be updated, including new benchmark calculations and support of ACO programs. For more information about the proposed rule and the various aspects involved, see the article found here.