By Wren Keber, Manager, The Camden Group
On Tuesday, March 10, 2015, the Centers for Medicare and Medicaid Services (“CMS”) announced a new Accountable Care Organization (“ACO”) model through its Center for Medicare and Medicaid Innovation ("CMMI"). The new model, called "Next Generation ACO," builds upon the experience gained with the Medicare Shared Savings Program ("MSSP") and Pioneer ACO Models. As with the two existing programs, the Next Generation ACO is a model for traditional fee-for-service ("FFS") Medicare, otherwise known as "Original Medicare."
The new model has some key differences from MSSP and Pioneer ACOs, which make the program attractive for organizations wishing to take on greater risk and be successful under such risk-bearing arrangements. Specifically, Next Generation ACOs will:
- Be subject to a new and improved benchmarking methodology, which rewards both attainment and improvement in cost containment. The benchmark ultimately transitions away from comparisons to an ACO's historical expenditures.
- Have the ability to choose from various payment methods - normal FFS payment, FFS plus a monthly infrastructure payment, population-based payments, or capitation. With all payment arrangements, Next Generation ACOs will have increased risk/rewards compared to MSSP and Pioneer ACOs. A Next Generation ACO will have the ability to transition from normal FFS to more complex methods over time.*
- Be able to deploy benefit enhancements for beneficiaries, including greater access to home/tele-health, and skilled nursing facilities ("SNFs"), opportunities for beneficiaries to receive a reward payment for receiving care from the ACO, and greater collaboration between CMS and ACOs to improve communication with beneficiaries.
- Have greater diversity in the types of affiliation arrangements to collaborate with providers who do not wish to fully participate in the ACO as a provider/supplier. The ACO can choose to partner with "Preferred Providers" and other "Affiliates," such as SNFs, to coordinate care and accomplish other ACO functions.
Additionally, beneficiaries will have the ability to proactively confirm or deny their attribution to a Next Generation ACO. According to CMS, "confirmations of care relationships through voluntary alignment [by beneficiaries] supersede claims-based attributions." This addresses the concern of high turnover in beneficiary alignment found in the Pioneer and MSSP models.
Is It For You?
CMS has indicated that the Next Generation ACO model is appropriate for organizations that have experience in coordinating care for populations of patients. This could include current MSSP or Pioneer ACOs, who have seen success in the program participation thus far. If a current Pioneer or MSSP ACO applies for participation in the Next Generation ACO, CMS will seek proof of positive performance and conduct under their current model. The Next Generation ACO may be appropriate for you if you are already experiencing success in the Pioneer or MSSP models, and you are seeking enhanced alignment opportunities with participants and beneficiaries, as well as increased risk and reward corridors.
Even if not already a Pioneer or MSSP ACO, health systems, integrated networks, and other providers may consider the Next Generation ACO model as an option to partner with CMS on an innovative value-based program. Experience in population health management and deployment of clinically integrated or patient-centered programs may lend well to success in the Next Generation ACO model, when coupled with experience with new payment models and management of the total cost of care for a population.
There will be two rounds of Next Generation ACOs, one round with a 2016 start date, and a second with a 2017 start date. CMMI will accept Letters of Intent ("LOIs") for 2016 starters through May 1, 2015. The documents for those applicants will be due by June 1, 2015.
To learn more about this model, or for help in determining if your organization is appropriate to apply for the Next Generation ACO model, please contact Wren Keber at The Camden Group at firstname.lastname@example.org . The Camden Group provides LOI and application support for organizations wishing to apply for the Next Generation ACO model.
*Per CMS, "to participate in the Next Generation ACO model, ACOs must demonstrate compliance with all relevant state laws and regulations with respect to risk-bearing entities."