CMS recently issued several major proposed rules affecting Medicare payments for physicians and hospitals in 2019. Taken as a whole, these rulemaking actions demonstrate a continued strong value proposition for hospital participation in Accountable Care Organizations in 2019 and into the future. Both the 2019 Physician Fee Schedule/Quality Payment Program (PFS/QPP) and the Outpatient Prospective Payment System (OPPS) proposed rules will allow ACOs to both operate free from some burdensome requirements and recoup some proposed payment cuts through shared savings.   

The PFS/QPP proposed rule signals some welcome stability to the MIPS Program. CMS is investing in and refining the program, despite persistent questions about its future. The cost domain will continue its incremental increase, going from 10 to 15 percent next year. Another piece of good news for our rural providers is the changes to MIPS to address our nation’s opioid crisis. There are also more ways for low volume providers to qualify for MIPS bonuses under this rule.  

Some of the ACO-specific changes will make participation more attractive for those providers who have been wary in the past. The rule would substantially reduce the number of quality measures, from 31 down to 24. This change would allow ACOs and member providers to focus more of their time on patient care, rather than time-consuming reporting requirements – though Caravan Health is concerned about the implications of removing the measure for testing of eye function for patients with diabetes.  

In the OPPS proposed rule, CMS proposed a dramatic reduction in rates for clinic visits at outpatient hospitals. Hospital groups and other have raised concerns about the site-neutral payment policies that began several years ago and are expanded in the proposed OPPS rule. While this policy may challenge some outpatient clinics, the best way to manage any payment reductions is by joining an ACO. ACO participation creates an opportunity to earn shared savings, effectively giving some of that money back to community providers and allowing them to stay afloat financially.  

Caravan Health is encouraged to see CMS continuing to create incentives for hospitals to join risk-bearing payment models. Despite lots of uncertainty this year, ACOs have been strengthened by these proposed rulemaking actions. Stay tuned for analysis of the new regulation for the Medicare Shared Savings Program, expected imminently.   

Learn More about ACO Success

Recent Articles and News

September 19, 2018

Thriving in Value-Based Payment Is a Team Effort – How ACOs Can Learn from Experience to Succeed

Health care is constantly evolving – new programs, requirements, and regulations are the norm. Caravan Health’s experts understand this environment and bring their unique perspective to making the most of payment and delivery system reform.

August 27, 2018

Webinar Recap – Strategic Implications of CMS’s Proposed ACO Rule

On Thursday, August 23, experts from Caravan Health held an informational webinar discussing the new CMS proposed rule about the future of Medicare Shared Savings Program Accountable Care Organizations.

Policy, CMS

August 10, 2018

Proposed Rule for Medicare ACOs Allows Upside-Only Participation With a Gradual Transition to Risk

High performing systems can continue to thrive in Medicare’s ACO program under CMS’s new proposal

Policy, CMS