More Groups Want to Extend Medicare Shared Savings Program Deadline

January 23, 2019 - Eleven healthcare industry groups are supporting the National Association of ACOs’ (NAACOS) call for CMS to extend the Feb. 19 application deadline for the Medicare Shared Savings Program (MSSP).

CMS announced earlier this month that the application cycle for the MSSP’s next iteration will launch Jan. 22. Accountable care organizations (ACO) wanting to participate in the MSSP’s Pathways to Success will have to submit their application by Feb. 19, 2019, at noon ET.

However, the non-profit association representing ACOs across the country pointed out that the MSSP application deadline is just two months after CMS published the 267-page final rule detailing the new Pathways to Success model.

The Feb. 19 deadline does not provide ACOs with enough time to digest the new MSSP rules and decide if the organization should participate in the new program launching July 2019, NAACOS said. The association urged CMS earlier this month to extend the deadline to later in March.

Now, eleven other industry groups are backing NAACOS and calling for a March 29, 2019 deadline.

READ MORE: For Ongoing ACO Shared Savings, Look Outside Inpatient, Primary Care

The organizations include the American Academy of Family Physicians (AAFP), American College of Physicians (ACP), America's Essential Hospitals, American Hospital Association (AHA), American Medical Association (AMA), America’s Physician Groups (APG), Association of American Medical Colleges (AAMC), Federation of American Hospitals, Health Care Transformation Task Force (HCTTF), Medical Group Management Association (MGMA), and Premier.

“Due to the complexity of CMS’s new final rule for the program published in the Federal Register on December 31, 2018, many existing ACOs and those in the process of formation are still actively working to understand how they may successfully participate in the program,” the groups recently wrote to CMS Administrator Seema Verma.

“Additional time is needed to ensure ACOs may evaluate their options and complete the administrative and legal requirements of the application. Without additional time, participation in this voluntary program will suffer.”

The new Pathways to Success initiative is a major overhaul of the MSSP. The new iteration of the largest Medicare ACO program will require ACOs to assume downside financial risk sooner compared to the original MSSP.

Most ACOs will have two years to assume downside financial risk, while organizations in the MSSP had up to six years to transition from an upside-only track.

READ MORE: 67% of MSSP ACOs May Be High-Revenue Under Pathways to Success

Pathways to Success will also reduce the number of program tracks from four to two, decrease the shared savings rates for upside-only ACOs to 40 percent, extend the length of agreement periods to at least five years, and offer telehealth and other waives to ACOs taking on downside risk.

CMS intends for the MSSP overhaul to support value-based care and reduce healthcare costs.

“Pathways to Success is a bold step towards quality healthcare at a lower cost through competition and beneficiary engagement,” CMS Administrator Seema Verma stated in the Dec. 21, 2018 announcement. “The rule strikes a balance between encouraging participation in the ACO program and advancing the transition to value, ultimately protecting taxpayers and patients. Medicare can no longer afford to support programs with weak incentives that do not deliver value. As we structure new payment arrangements, the impact on the overall market will be top of mind.”

Pathways to Success may be the key to advancing the successes and overcoming the challenges of the MSSP. But industry leaders are concerned that the Feb. 19 deadline will ultimately jeopardize the program’s success.

MSSP ACOs have told the industry groups that it will be “challenging, if not impossible” to meet the deadline in four weeks.

READ MORE: How Next Generation ACOs Built a Foundation for Success

ACOs include a network of different providers. The organizations need to obtain buy-in from each ACO participant, boards, and leadership teams to move forward with the MSSP application. For some ACOs, completing an application will require sign-off from nearly 200 unique sets of providers, boards, and governing bodies.

Additionally, ACOs must work with actuaries to identify participation options, the groups explained. The organizations must determine if taking on downside financial risk sooner under new MSSP rules is the appropriate path.

The accelerated pathway to downside financial risk will also require many ACOs to obtain guarantees from banks and other financial organizations. Unfortunately, financial institutions are unfamiliar with CMS deadlines and can take up to six weeks to give ACOs the information they need.

“We understand the time constraints CMS must operate within but ask that you keep in mind that this truncated timeline could harm program participation and we encourage the agency to consider a March 29, 2019 deadline,” the groups wrote. “Our recommendation reflects our unified desire to see the MSSP maintain long-term sustainability necessary to enhance care coordination for millions of Medicare beneficiaries, lower the growth rate of healthcare spending and improve quality in the Medicare program.”