Accountable Care Organizations

Feb 18-22: Most New ACOs to Face Higher Risk, Analyses Say

February 15, 2019 7:33 am

This week, CMS identified the 487 ACOs that renewed their participation through the July start of the new ACO rule.

Feb. 14—Most organizations applying by next week to launch accountable care organizations (ACOs) this summer may be required to take on higher levels of financial risk, according to two analyses.

An overhaul of Medicare’s main accountable care organization (ACO) program was finalized in mid-December, and many providers looking to join or continue participating must meet a Feb. 19 application deadline. ACOs that have opted to continue under old contracts will not be affected. The Centers for Medicare & Medicaid Services (CMS) posted additional required actions here.

After CMS on Dec. 21 issued a final rule revising the Medicare Shared Savings Program (MSSP), some industry leaders warned that the new rules could reduce the number of organizations participating in the program, which was intended to lead an industry-wide redesign of care delivery. Those still interested have been scrambling to apply.

“Many have expressed concern they won’t be able to get everything signed, sealed, and delivered by Tuesday,” said a spokesman for the National Association of ACOs (NAACOS). “But CMS, despite being unlikely to change the Feb. 19 deadline, is giving a lot of flexibility to file and finalize different parts of applications during the back-and-forth CMS has with ACOs.”

Hospital- and physician-advocacy groups wrote CMS a letter in January to request that the ACO deadline be postponed to March 29.

CMS had set a January deadline for prospective ACO applicants to file letters of intent to participate under the new rules but would not say how many it received.

This week, CMS quietly posted the names of the 487 ACOs that renewed their participation through the July start of the new ACO rules. A CMS official previously said 90 percent of the organizations eligible to renew had done so.

Controversial Provision

Among the controversial elements of the new rules was the first-time designation of high-revenue and low-revenue ACOs and differing rules for each. The differentiation stemmed from CMS’s contention that larger entities had greater control over beneficiary spending and could better control Medicare costs, so they should move into the risk-bearing phase faster.

High-revenue ACOs were defined as those with total Medicare fee-for-service (FFS) revenue of at least 35 percent of the total Medicare FFS spending for the ACO’s assigned beneficiaries. Low-revenue ACOs were defined as those with less than 35 percent.

The distinction determines program specifics, such as the speed with which the ACO will need to take on financial risk. Specifically, high-revenue ACOs will be required to move to the Enhanced Track after one (five-year) agreement period in the Basic Track, while certain low-revenue ACOs can remain in the Basic Track for two agreement periods.

A NAACOS analysis of existing MSSP ACOs in 2016, which was shared with HFMA, found 58 percent, or 249, of the 432 Medicare ACOs at that time would have fallen into the high-revenue category.

A Leavitt Partners analysis of 550 of the 560 existing MSSP ACOs found 67 percent could potentially be designated high-revenue.

Both analyses found that the breakdown of ACOs did not always follow the assumption that hospital-led ACOs would be high-revenue and physician-led ACOs would be low-revenue.

“As ACOs consider entering the MSSP under the new Pathways rule, they must recognize the strong possibility that they will end up being designated high-revenue under Pathways and be required to assume downside risk more quickly,” David Muhlestein, chief research officer for Leavitt Partners, said in a release.

ACOs will not know their revenue status until after they formally apply for the program.

The NAACOS analysis found almost 20 percent of physician-led ACOs would be considered high-revenue. Some federally qualified health centers and rural health clinics also would be categorized as high-revenue ACOs.

In a separate Medicare ACO development, Seema Verma, administrator of CMS, this week announced that CMS will begin sharing claims data for ACO participants with those organizations in a bulk format. Verma said the project will use the Fast Healthcare Interoperability Resources Bulk Data Spec but did not provide details.

Monday, Feb. 18

Deadline to apply for the HFMA MAP Award for High Performance in Revenue Cycle, which recognizes organizations with innovative and effective approaches to achieving excellence in revenue cycle performance. Learn more.

Tuesday, Feb. 19

Webinar sponsored by America’s Health Insurance Plans (AHIP) titled “A Better Way for Member CX.” Learn more.

Wednesday, Feb. 20

Webcast by the USC-Brookings Schaeffer Initiative for Health Policy titled “Emerging Policy Solutions to Surprise Medical Bills.” Learn more.

Webinar by the American Hospital Association titled “Successfully Implementing Bundled Payments.” Learn more.

Webinar by the Centers for Medicare & Medicaid Services (CMS) titled “The Hospital Outpatient Quality Reporting Program Program: Back to Basics.” Learn more.

Webinar by the National Academy of Medicine titled “Procuring Interoperability.” Learn more.

16th Annual Healthcare and Life Sciences Private Equity and Finance Conference in Chicago (through Feb. 21). Learn more.

Webinar by the Catholic Health Association titled “IRS Form 990, Schedule H: An Overview.” Learn more.

Thursday, Feb. 21

Webinar by America’s Physician Groups titled “A Deep Dive on Part II of the Medicare Advantage Advance Notice.” Learn more.

Webinar by CMS titled “Quality Payment Program: Overview of APMs for Year 3.” Learn more.

Webinar sponsored by AHIP titled “Curing Chronic Condition Complexity for America’s Seniors.” Learn more.

2019 Population Health Management Summit for Payers & Providers in Miami (through Feb. 22). Learn more.

Webinar by the Catholic Health Association titled “Eldercare Webinar: Trauma-informed Care—Practical Implications.” Learn more.

Friday, Feb. 22

National Governors Association’s 111th annual Winter Meeting in Washington, D.C. (through Feb. 25). Learn more.


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