January 16, 2019


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With CMS recently finalizing the MSSP ACO rule, there is a lot for successful organizations to understand. This is one in a series of blog posts explaining the MSSP ACO final rule in greater detail. If you haven’t already, check out the recent webinar hosted by Caravan Health policy experts.  

What are the three most critical things for ACOs to know going into 2019? 


1. All MSSP ACOs will eventually be on a faster path to risk 

The major change for the program is the shift from current tracks 1, 1+, 2, and 3 to the new Basic and Enhanced tracks. The 3-year agreement periods at one single risk level will be replaced by 5-year agreement periods that will provide greater stability and predictability in producing savings. Risk for providers will increase nearly every year until the ACO reaches a moderate level of downside risk comparable to the prior track 1+ model. These new tracks will offer a 40 percent shared savings rate in the earliest years. The benchmark will take regional factors into account in the first agreement period which can help providers that have higher than expected costs or are over-represented in their geographic area.  

2. ACOs are still a great way to improve quality and cut costs 

CMS has made it clear that value-based payment is here to stay. With the introduction of MIPS and the other changes to Medicare payment in recent years, providers must plan for a future of delivering value rather than just volume. This final rule shows a commitment from CMS to making the Medicare Shared Savings Program sustainable, even for small and rural providers that may not feel ready for the shift. The new glidepath to risk is ultimately a vote of confidence in the ACO model. There are lots of good options and opportunities for existing ACOs and those considering entering the program for the first time.  

3. Some big deadlines are approaching fast 

An important note – many ACOs won’t need to do anything right away in response to the final rule. If your ACO has already started an agreement period in track 1, 1+, 2, or 3 in 2017 or 2018, you don’t need to take any action to complete your participation in your current ACO.   

If you are planning on a July 2019 start, there are some important dates to know. An ACO that plans to begin a new agreement period under the Basic or Enhanced track starting in July 2019 will have to submit a non-binding Notice of Intent to Apply (NOIA) by this Friday January 18, 2019 at noon ET. The NOIA is required before applying to operate a Shared Savings Program under the new rules, as well as for a SNF 3-Day Rule Waiver or to establish a Beneficiary Incentive Program (BIP) for risk-bearing tracks. The SNF waiver and BIP are options available to certain ACOs in two-sided risk arrangements.  

After the NOIA is complete, a full application is due no later than February 19, 2019 at noon ET. The full application is a lengthier and more involved process than the NOIA and requires applications to provide information including: 

  • ACO leadership and governance details 
  • Program option selections, such as track and level, beneficiary assignment methodology, and risk corridors 
  • A list of participating providers 
  • Plans for distributing any shared savings earned 

Caravan Health is here to help 

Caravan Health can work with you to figure out the best way to move forward under the new rules. Get in touch with us at info@caravanhealth.com for more information.  

Much more to come about the final rule 

There are a lot more details in the final rule to explore. Next week, we will tackle the new high and low revenue definitions and what those mean for your organization.   


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