September 26, 2018


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We’re constantly adapting our strategies to meet the evolving rules and regulatory policies in the health care industry. Staying abreast and ahead of change keeps our clients sustainable and profitable in Medicare Shared Savings Program (MSSP) ACOs. Most recently, we’ve focused on the CMS proposed rule changes from August 2018, digging into the potentially major changes, strategic implications, and 2018-on timeline. In the midst of these efforts, we find the value-based care community asking some important questions, and we want share the answers with you here:

Not seeing the right questions or answers?
 We want to hear about it.


What course of action do you recommend for smaller ACOs?

Regarding program options in 2019 and beyond, we suggest everyone who is currently in an ACO, regardless of size, stay in their current arrangement until their agreement periods end. This means your ACO will continue under the rules you are familiar with for as long as possible. If you are up for renewal in 2019, we can help you understand your options for how to handle an accelerated risk path.
When it comes to small ACOs in particular, however, our data and experience tell us that those with 100,000 or more lives are best positioned to truly succeed in shared savings.
How Caravan Health Can Help:
We match organizations with others to aggregate lives into Collaborative ACOs to maintain independence and enforce accountability.


What do CMS changes to ACO rules mean for our ACO?

CMS is constantly refining the ACO program, but although change is expected, it doesn’t mean it’s easy to adapt to when it happens. The impact of the rule on ACO participants varies by specific circumstances. For example, in 2018, CMS proposed rule changes to take effect in 2019 (and following years). In this case, we advise current ACOs not to panic about moving into risk faster. There are still plenty of good options for ACOs to learn the ropes before taking on two-sided risk.
How Caravan Health Can Help:
We understand the policies and rules, so we can help you find the best options for your specific organization and unique needs.


How do CMS rules impact rural ACOs?

Some of the strongest results in the ACO program come from rural ACOs. The mostly rural ACOs in the ACO Investment Model (AIM) program actually demonstrated higher savings than those in Track 3 for 2017. However, to answer this question is primarily determined on an individual basis. Things that might impact your participation as a rural ACO include:

  • Is your ACO considered new or renewing?

  • If renewing, does this impact the level at which you can (and should) return?

  • Is your ACO low revenue or high revenue?

How Caravan Health Can Help:
We’ve worked with more than 14,000 clinicians nationwide to develop clear ways to help all ACO participants achieve financial success.


What determines if our ACOs are “low revenue”? Is it the same as “rural”?

In short, low revenue is not the same as rural. CMS uses the terms low and high revenue to talk about the share of the beneficiary’s health care costs that is under the control of the ACO. For example, the August 2018 proposed rule states that small, physician-only and rural ACOs are likely to be considered low revenue. It will allow these ACOs to spend more time, possibly as much as an extra year, in a one-sided risk arrangement.
How Caravan Health Can Help:
Although revenue status won’t mean much yet, we help clients get ahead and stay ahead by using advanced reporting and analytics to drive success.

What are the upsides and downsides of the ACO options (tracks, risk, levels, etc.)?

Each time CMS makes changes, there are bound to be pros and cons for all involved – that’s inevitable. Most recently, the August 2018 proposed rule changes lowered the shared savings from 50 percent in the Track one level to 25 percent for brand-new ACOs. This could be considered a downside, but CMS also left some attractive low-risk models on the table, which is certainly an upside.
Regardless of which path an ACO is in, we find that our ACOs perform well because we help them function outside of the pros and cons. Instead, we guide them to focus on the overall benefits of being in an ACO:

  • Access to data on a tremendous scale that is otherwise unavailable outside the MSSP.

  • Improving care quality and patient outcomes with a network of physicians, clinicians, hospitals, and others caring for patients in their communities.

  • Streamlined and preferential treatment under MIPS.

How Caravan Health Can Help:
We drive clients toward success by aiming at the true goal: bringing population health to life.

Throughout all the rule and regulatory changes, we are helping our clients maximize financial success and minimize risk, that’s what we are here for. We can and will help you succeed in value-based care, too. 

Let’s talk about your options. Contact us to learn more.

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