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8/21/18

NAACOS' In-depth Review of the ACO Proposed Rule

DescriptionNAACOS staff will provide an in-depth review of the recently proposed changes to the Medicare Shared Savings Program (MSSP). This critical regulation makes proposed changes to overhaul the current MSSP Tracks to instead offer a "Basic" or "Enhanced" Track. In the webinar, staff will review key proposals including CMS proposals to:

  • Provide flexibility to allow ACOs that are ready to accelerate their move to higher risk within agreement periods, and enable such ACOs to qualify as Advanced Alternative Payment Model (APM) entities for purposes of the Quality Payment Program.
  • Modify the participation options by retiring Track 1 and Track 2 and introducing a new BASIC track that includes a gradual shift to risk. The glide path to risk in the BASIC track includes five levels, with a one-sided model available only for the first two years to eligible ACOs.
  • Retain Track 3, which would be renamed as the ENHANCED track, to encourage ACOs that are able to accept higher levels of potential risk and reward to drive the most significant systematic change in providers' and suppliers' behavior.
  • Modify agreement periods from three years to five years.
  • Establish policies to deter gaming by limiting more experienced ACOs to higher-risk participation options.
  • Modify methodologies related to benchmarking, including accelerating the use of factors based on regional fee-for-service expenditures and risk adjustment.
  • More rigorously screen for good standing among ACOs seeking to renew their participation in the program or re-enter the program after termination or expiration of their previous agreement.
  • Identify ACOs re-forming under new legal entities as re-entering ACOs if greater than 50 percent of their ACO participants have recent prior participation in the same ACO in order to hold these ACO accountable for their ACO participants' experience with the program; and hold ACOs in two-sided models accountable for partial-year losses if either the ACO or CMS terminates the agreement before the end of the performance year.
  • Implement provisions of the Bipartisan Budget Act (BBA) that allow for certain telehealth waivers and beneficiary incentive programs and broaden access to the current SNF 3-day waiver for risk bearing ACOs.
  • Seek feedback on changes to quality measurement approaches for ACOs.
  • Adjust the 2019 application process and allow for an abbreviated performance year in 2019 of six months.
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