- As part of its 2017 advocacy agenda, the National Association of Accountable Care Organizations (NAACOS) released policy recommendations for ACO improvement. The recommendations included Medicare Shared Savings Program (MSSP) changes, one-sided financial risk model promotion, a mechanism to account for ACO investment, and less regulatory burden.
“Because of the importance of ACOs in healthcare delivery, NAACOS continues to advocate for policies that would improve how beneficiaries receive their care, as well as allow our ACOs to flourish in this program,” stated the industry group.
A major area of focus in 2017 will be Medicare ACO improvements, NAACOs stated. CMS oversaw over 470 Medicare ACOs in 2015, resulting in over $466 million in total healthcare savings. Building on Medicare ACO success, NAACOS plans to advocate for several MSSP changes, such as implementing the MSSP Track 1+ model, addressing risk adjustment limitations, and reducing problematic interactions with other CMS programs.
In December 2016, CMS unveiled the MSSP Track 1+ model that will contain more financial risk than Track 1, but less than Tracks 2 and 3. The federal agency intends for the limited financial risk ACO model to help providers gradually take on more risk and participate more in the Advanced Alternative Payment Model track of the Quality Payment Program.
NAACOS remains committed to ensuring that a wide range of ACOs are eligible to participate in the new MSSP track. For example, the industry group wrote to CMS in December 2016 calling on the federal agency to allow MSSP ACOs to move into Track 1+ at the start of any performance year, rather than wait for the start of their next three-year agreement period. The group also urged CMS to make the track available to ACOs regardless of composition.
“We feel that Track 1+ represents a missing link in the Medicare ACO program,” wrote NAACOS in its 2017 agenda.
In addition to supporting the new limited financial risk MSSP track, NAACOS also put more general MSSP risk adjustment changes on its 2017 advocacy agenda. Specifically, the industry group called for CMS to allow risk scores to increase year-over-year for beneficiaries continuously assigned to the ACO.
CMS should also address how the MSSP interacts with other CMS programs, NAACOS added. MSSP and some Medicare value-based reimbursement models conflict, causing the ACO to lose out on potential shared savings.
For example, a June 2016 NAACOS report stated that some Medicare bundled payment models conflict with the MSSP. When ACO patients are treated under a bundled payment program, ACOs lose the financial accountability for that patient.
The federal agency should develop formal shared savings agreements that resolve problematic interactions between Medicare value-based reimbursement programs and incentivize the two programs to coordinate care, NAACOS recommended. However, CMS should prioritize models that promote population health management, such as ACOs.
While NAACOS expressed support for the MSSP Track 1+ model’s limited financial risk structure, the industry group also plans to promote more one-sided financial risk model participation.
About 90 percent of Medicare ACOs are involved in one-sided financial risk models, the advocacy agenda stated.
A recent Leavitt Partners study also found that 61 percent of ACO contracts in general are one-sided risk-only, indicating most ACOs are either risk-adverse or are still experimenting with adding risk.
CMS, however, intends to push more ACOs to take on additional risk. For instance, MSSP Track 1 ACOs, which are upside-only models, must move into a track with more financial risk after two agreement periods.
In 2017, NAACOS intends to promote one-sided risk models, particularly by urging CMS to allow Medicare ACOs to remain in the MSSP Track 1 model for more than two agreement periods.
Additionally, NAACOS will prioritize the development of a mechanism that accounts for ACO investments. The June NAACOS report found that ACOs invested approximately $1.6 million per year on average to participate in the model and improve care delivery models.
However, CMS currently does not include ACO investments as part of the organization’s financial risk nor does the federal agency take the investments into account when determining shared savings payments.
NAACOS suggested that CMS use ACO investments when deciding if an ACO’s risk levels qualify for Advanced Alternative Payment Model participation.
Another ACO improvement priority in 2017 will be limiting regulatory burdens, which would give ACOs “greater flexibility to focus on coordinating care for beneficiaries rather spending time meeting onerous government requirements.”
The industry group already expressed support for the ACO Improvement Act of 2016, which offers ACOs more options for participation. For example, the act would allow for primary care cost-sharing, waive telemedicine limitations, and offer ACOs a prospective and retrospective beneficiary assignment option.
House representatives introduced the ACO Improvement Act of 2016 in September, but the act has not been passed by either lawmaking body.
“We look forward to reintroducing similar language in 2017 and working with Congress to sign it into law,” stated NAACOS.