October 02, 2018

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This post was originally published in Healthcare Informatics 

by Lynn Barr CEO and Founder of Caravan Health


In the accountable care community, we’re all anticipating the potential impacts of the recently proposed Medicare Shared Savings Program (MSSP) ACO (accountable care organization) rule.

Although there’s some uncertainty about what the final rule will look like, what is certain is that clinical, hospital, and health system leaders need to understand what’s happening, what to expect from CMS (the Centers for Medicare & Medicaid Services), and when to expect it. To help with that, we identified the key dates and points you need to know below.

August 2018: Proposed New Risk Glidepath, Changes for Upside-Only ACOs

The proposed rule from CMS was published in August of 2018. It incorporated a new structure for MSSP ACOs, including potential major changes to:

  • Tracks
  • Risk paths
  • The SNF 3-day stay waiver
  • Telehealth options
  • The Beneficiary Incentive Program

Still, CMS could do a lot more to ensure providers in rural and other underserved areas are encouraged to continue their success in the ACO program.

Get the full details about the changes in our blog here.

October 16, 2018: CMS Proposed Rule Comment Period Closes

With the proposal out, CMS will take public comments until October 16, 2018. It’s critical that health care leaders take advantage of this opportunity to voice their views, concerns, and suggestions on the proposed rule. The easiest way to submit comments is electronically at www.regulations.gov. The future of the program can absolutely be affected by the comments CMS receives, which is why Caravan Health is developing comments for submission. We also strongly encourage our own ACO participants and everyone with a stake in accountable care to submit comments. Don’t miss out on this opportunity to influence the final rule.

December 2018 or January 2019 (likely): Finalizing the Proposed ACO Rule 

Once the comment period closes, CMS will enter a review and revision period. The agency will likely not make public statements about rule revisions during this time and will probably publish a final rule sometime late this year or early next year.

Spring 2019 and June/July 2019: CMS 2019 Application and Start Date Options

The press release from CMS announcing the proposed rule reads:

  • CMS proposes a 6-month extension for current ACOs whose agreements expire at the end of 2018, along with a special one-time July 1, 2019 start date that will have a spring 2019 application period for the new participation options.

In short, the delayed timeline means that CMS has built an additional six months into the process by starting the 2019 plan year in July rather than January. This also impacts the application period, which will be finalized along with the rule.

2018 and 2019: ACOs Must Plan and Act Now

Now that 2017 data from CMS has been released, we’ve seen that the program is bringing tremendous financial success to many of our ACO participants. We want healthcare leaders to be confident that hospitals can and will continue to thrive in ACOs. The financial and quality benefits of the program, when we all emphasize accountability, have been proven time and again. Patient outcomes and satisfaction ratings continue to increase far more in ACO member organizations than in those not in ACOs. It’s vital for organizations to continue to band together, eliminating undersized ACOs, and bringing better care to patients.

If you want to talk about the proposed rule and the potential implications for your organization, we have experts from every corner of the industry ready to answer your questions and help you understand your options. Email us directly at info@caravanhealth.com or call us at (916) 542-4582.

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