Sliding in just under the wire of the anticipated government shutdown, CMS has released the Shared Savings Program final rule. With the rule, CMS finalized many changes to the ACO program as proposed in August, including an increase from three to five years of participation under a contract and the elimination of tracks 1, 2, and 3 in favor of Basic and Enhanced options.
The rule reflects some positive changes based on Caravan and other stakeholder comments, most notably an increase in the shared savings rate in the Basic option to match more closely what is currently available to providers in Track 1 ACOs. Additionally, CMS heard Caravan’s comments regarding rural providers and adjusted the proposed low-revenue threshold to include ACOs with participant Medicare fee-for-service revenue of less than 35 percent of the total. This will allow more small ACOs, including more rural ACOs, to remain at the Basic option’s no-risk levels for three years instead of two. A summary table of the Basic and Enhanced options is provided at the bottom on this post.
Other provisions Caravan found promising were finalized with no changes such as benchmarking methodology that will more accurately allow for upward risk adjustment over time and better incorporate regional variation from national expenditures. In two-sided risk tracks under the new model, CMS will make new options available to help ACOs manage the care of their patient population such as telehealth services to the patient’s home, monetary incentives for patients to receive primary care services, and waivers from the 3-day inpatient stay requirement prior to skilled nursing facility admission.
The new model will be available as soon as July 1, 2019 and January 1 of subsequent years. Providers interested in a July 1, 2019 start must complete a non-binding Notice of Intent to Apply (NOIA) between January 2 and January 18, 2019.
Tune into our webinar to hear from Caravan Health President Tim Gronniger and Policy & Compliance Officer LeeAnn Hastings as they discuss these and other changes in the final rule.
Watch the webinar now
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BASIC
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ENHANCED
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Level A
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Level B
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Level C
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Level D
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Level E
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Risk
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Upside only
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Two-sided
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Two-sided
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Two-sided
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Two-sided
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Shared Savings
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1st dollar savings, rate of 40%
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1st dollar savings, rate of 50%
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1st dollar savings, rate of 50%
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1st dollar savings, rate of 50%
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1st dollar savings, rate of 75%
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Shared Losses
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NA
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1st dollar losses, rate of 30%, not to exceed 2% of revenue or 1% benchmark
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1st dollar losses, rate of 30%, not to exceed 4% of revenue or 2% benchmark
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1st dollar losses, rate of 30%, not to exceed nominal risk standard (currently 8% of revenue or 4% of benchmark)
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1st dollar losses, rate of 1 minus sharing rate (40-75%), not to exceed 15% of benchmark
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QPP Status
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MIPS APM
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Advanced APM
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Advanced APM
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Attribution Choice Prospective / Retrospective
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Yes
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Yes
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Beneficiary
Incentives
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No
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Yes
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Yes
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Telehealth
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No
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Yes, with prospective attribution
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Yes, with prospective attribution
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SNF Waiver
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No
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Yes
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Yes
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