Pathways to Success

Background 

The Centers for Medicare & Medicaid Services (CMS) finalized on December 21 an overhaul to the Medicare Shared Savings Program (MSSP), Medicare’s largest value-based payment program, which it calls Pathways to Success. Many of the concessions CMS made in the final rule were the result of NAACOS advocacy, such as an additional year in shared savings-only models for some new ACOs, higher shared savings rates, and in increase in the threshold in distinguishing high and low revenue ACOs. The final rule contains several other positive changes including increased flexibility in choice of assignment methodology, longer, five-year agreement periods, and more waivers like that for telehealth and skill nursing facility stays. While an improvement over the proposed rule, the final rule still includes several challenges like less time in shared savings-only or low risk models than the program offers currently and distinguishing between high and low revenue ACOs.

The rule can be accessed here along with a related CMS factsheet and press release. Click the image to the right for our in-depth analysis of the rule, detailing everything ACOs need to know about the final changes. Additional information on the MSSP can be found on this NAACOS page. NAACOS continues to advocate for polices that ensure the long-term success of Medicare ACO programs and educate members on the rule and what it means to them. 

NAACOS Member Resources 

• NAACOS chart comparing Direct Contracting and other high-risk ACOS
  
  
• Timeline Reviewing Key Dates for ACOs in 2019
  
  
• NAACOS review assesses the impact of high-low revenue designations
  
  
• NAACOS releases in-depth analysis of the final Pathways to Success rule
  
  
• Frequently Asked Questions on the Final Pathways to Success Rule
  
  
• NAACOS statement on the final Pathways to Success rule
  
  
• Interactive spreadsheet to estimate shared savings and losses under the various track options 
  
  
• NAACOS Webinar Review of ACO Pathways to Success Provisions included in the Medicare Physician Fee Schedule Rule 
  
  
• NAACOS Review of ACO Pathways to Success Provisions included in the Medicare Physician Fee Schedule Rule 
  
  
• NAACOS ACO Comparison Chart updated for 2019 to reflect the new Pathways structure and old MSSP structure

CMS Resources

• 2019 MSSP application details from CMS’s website
  
  
• CMS Releases 2019 MSSP Report Schedule
  
  
• Key deadlines and action dates for 2020 applicants issued by CMS
  
  
• MSSP application details from CMS’s website
• Notice of Intent to Apply guidance
• MSSP participation options
• Beneficiary Incentive Program guidance 
• Skilled Nursing Facility (SNF) 3-Day Rule waiver guidance
• CMS released the application toolkit and RFI response actions and deadlines
• ACO participant lists and participant agreements guidance 
• Repayment mechanisms guidance 
• ACO banking form guidance 

Proposed Rule

• NAACOS submitted a 39-page comment letter on the proposed CMS Pathways to Success rule
• NAACOS press release on its final comments and related ACO poll about proposed Pathways to Success rule 

• A survey of all current MSSP participants polled ACOs’ feelings about the proposed rule 

• NAACOS developed this in-depth analysis and a shorter, one-page summary of the 166-page proposed regulation
• Table 2 from the proposed rule shows new MSSP options

• The popular Regulatory Update from the NAACOS fall conference provides another review of the proposed Pathways to Success rule and other policy updates. 
  
  
• NAACOS Statement on the proposed rule after the initial Aug. 9 release 

News and Advocacy

2019

• NAACOS-led letter to CMS urges a delay in the Feb. 19 MSSP application deadline
  
  
• The application deadline for July 1, 2019 starts is February 19
  
  
• NAACOS released a statement calling for CMS to extend the deadline into March
  

• CMS finalizes several MSSP-related policies in the final 2019 Physician Fee Schedule and MACRA rule here. A CMS factsheet is here. 
  
  
• The November 1 CMS ACO Spotlight Newsletter provides an update on MSSP changes in the 2019 Physician Fee Schedule and Quality Payment Program final rule, including updates on extending contracts that expire at the end of 2018 for another six months. 

• Lawmakers ask for key changes in final Medicare ACO regulation

• Nine stakeholder groups urge CMS to ensure continued success of ACO program
  • The NAACOS press release on the letter 

• NAACOS member testified before a House subcommittee to discuss the proposed rule 
  
  
• ACOs Saved Medicare $2.7 Billion from 2013-2016

• A NAACOS-commissioned study showed ACOs saved Medicare $1.84 billion from 2013 to 2015
• 2017 performance data from CMS shows positive results, prompting NAACOS statement
  
  
• NAACOS resource includes highlights of the 2017 MSSP results