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CMS Makes a Big Splash with Verma’s Speech, But What Does It Really Mean?

March 8, 2018
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Seema Verma and Alex Azar made high-profile speeches this week—but what might happen next?

She couldn’t have picked a better moment, or a better venue: when Seema Verma, Administrator of the federal Centers for Medicare and Medicaid Services (CMS), got up to speak on Tuesday morning at HIMSS18, unfolding here in the Sands Convention Center in Las Vegas, she had the entire healthcare IT industry, and much of the U.S. healthcare industry more broadly, listening to her.

And what Verma had to say was substantive, announcing the launch of a new initiative called “MyHealthEData,” aimed at revolutionizing the relationship of U.S. healthcare consumers to their patient data. As the announcement, published on the CMS website at about the same time Verma was speaking at HIMSS18, said, “Last year President Trump issued an Executive Order to Promote Healthcare Choice and Competition Across the United States. In response the Administration is moving towards a system in which patients have control of their data and can take it with them from doctor to doctor, or to their other healthcare providers. The government-wide MyHealthEData initiative is led by the White House Office of American Innovation with participation from the Department of Health and Human Services (HHS) – and its Centers for Medicare & Medicaid Services (CMS), Office of the National Coordinator for Health Information Technology (ONC), and National Institutes of Health (NIH) – as well as the Department of Veterans Affairs (VA). The initiative is designed to empower patients around a common aim - giving every American control of their medical data. MyHealthEData,” the CMS announcement said, “will help to break down the barriers that prevent patients from having electronic access and true control of their own health records from the device or application of their choice. Patients will be able to choose the provider that best meets their needs and then give that provider secure access to their data, leading to greater competition and reducing costs.”

Verma spoke passionately about the need to give healthcare consumers/patients more control over their data and information, citing an experience she had had personally, when her husband suffered heart failure while she was traveling, and when as a result, a series of unfortunate developments took place that might have unfolded very differently had she, as the spouse of a patient in an emergency medical situation, been empowered to access her husband’s data to support his emergency care.

“The reality,” Verma said, “is that once the information is freely flowing from patient to provider, the advances in coordinated, value-based care, will be greater than anything we could imagine today. Things could have been different for my family if my husband could have authorized me to have his health records on his phone,” she said. “Or if he could have notified me that he was in distress. And better yet, maybe we could have predicted his cardiac arrest days before, if his watch could have tracked his health data, and sending that data to alert his doctor, and possibly prevent what happened. My husband is part of the 1 percent that survives his condition. We shouldn’t have to depend on chance” for that type of outcome, she emphasized.

Moving back to the federal policy level, Verma told her audience Tuesday that, “Through the MyHealthEData initiative, this administration is focused on putting patients first, truly first, by giving them the information they need to truly improve their health. This administration will pull every lever to create a health information ecosystem that tailors the health system” to improve outcomes. And she insisted that “Our administration is completely aligned”—including across the Veterans Administration healthcare system, the Department of Defense, and other healthcare-related federal agencies—to achieve this goal. And the time is now. Hospitals and doctors” have extensive access to electronic patient records, she noted, “and nearly everyone has access to a smartphone. And smartphones in particular create the portability needed to create mobility… Uniform standards being drafted in the 21st Century Cures Act that will allow for information-sharing. The technology and regulatory requirements are finally coming together,” she emphasized.

Azar reinforces Verma’s message, with one of his own

Meanwhile, Verma’s speech turned out to not have been an isolated event this week, as federal healthcare officials made comments that reinforced her points, in a variety of venues and situations. Alex Azar, the new Secretary of Health and Human Services, caused his own splash this morning with a speech given in Washington, D.C. for America’s Health Insurance Plans (AHIP). According to the transcript of the speech that HHS posted on its website this morning, Azar said, among other things, that “This administration and this President are not interested in incremental steps. We are unafraid of disrupting the system simply because it’s backed by powerful special interests.”

Indeed, Azar said in his prepared remarks at AHIP, “[T]oday, I want to lay out four particular areas of emphasis that will be vital to laying down new rules of the road, accelerating value-based transformation, and creating a true market for healthcare. The four areas of emphasis,” he said, “are the following: giving consumers greater control over health information through interoperable and accessible health information technology; encouraging transparency from payers and providers; using experimental models in Medicare and Medicaid to drive value and quality throughout the entire system; and removing government burdens that impede this transformation. The key theme uniting these four priorities,” he added, “is the recognition that value is not accurately determined by arbitrary authorities or central planners.”

Higher up in that speech, Azar had placed all of this into a policy context, saying, “This is no time to be timid. Today’s healthcare system is simply not delivering outcomes commensurate with its cost — President Trump knows it, and the American people know it, too. But there is a better way. Imagine a day when healthcare delivery in the United States functions the way other parts of our economy do. We as patients would pick providers with the level of information we have when using Amazon or Yelp. Consumers would drive quality and cost-effectiveness with information, competition and genuine choice. Some argue healthcare is simply different, that it is and should be immune from market forces. I simply disagree. Real competition—in the economic sense—has never really been fully tried in our system.” And he added that, “Upon taking office at HHS, I identified the value-based transformation of our entire healthcare system as one of the top four priorities for our department. The others are combating the opioid crisis; bringing down the high price of prescription drugs; and addressing the cost and availability of insurance, especially in the individual market.”

Azar had actually made many of the same points on Monday, when he addressed the 2018 FAH Public Policy Conference and Exposition in Washington, D.C., a gathering of the Federation of American Hospital Systems—the national association of for-profit hospital organizations.

How will all of this play out? Some implicit public policy contradictions

So the question naturally arises, how will all of this play out, in the real world? Some of what Azar and Verma said in their speeches at HIMSS and AHIP this week are “mom and apple pie” notions—the idea that healthcare consumers might be able to drive quality and cost-effectiveness through making informed choices; on the other hand, they are also implicitly marrying two arguably contradictory, or at least, strongly contrasting, concepts—the ideas of market-driven change and federal government-compelled healthcare industry transformation.

Certainly, administrations of both political parties in the United States have struggled to master the challenges facing the U.S. healthcare system, which is arguably easily the most complex healthcare system in the world, by far. U.S. healthcare is neither a true free-market economic system, nor is it a completely government-run one; it is the strangest kind of hybrid one could possibly imagine—a fact frustrating to those on the political right and on the political left, and everywhere in between.

So here’s the nub of the profound question facing Azar, Verma, and everyone else in this administration, at the highest levels of federal healthcare policy: can the precisely right combination of federal government interventions force the U.S. healthcare system to respond in a “market-driven” way? In a “consumer-driven” way? That’s the gamble these federal healthcare officials are taking, both rhetorically and strategically. It’s one thing to say that healthcare consumers, armed with more data and information, and in control of their own patient records, will force the nation’s health insurers, hospitals, physicians, and all the other types of healthcare entities, to provide higher-quality, more efficient, more cost-effective, more consumer-centric, more satisfying care delivery, care management, and the like. But will that be the reality?

There seem to be two things missing here. First is addressing the issue of universal, or at least near-universal, health insurance coverage. This is an administration whose stated goal remains to repeal the Affordable Care Act, still the only vehicle designed at the federal level to broadly expand health insurance coverage in this country. And if healthcare consumers lack insurance, they literally have virtually no power in a market-driven healthcare system. Second is the assumption that providing healthcare consumers with more data and information, in itself, will fully empower them. Lots of people—from across the political spectrum—would regard that justifiable skepticism. Even Verma herself seemed to acknowledge the point, when, in announcing the creation of “Blue Button 2.0,” she noted that under the initial version of the Blue Button program, Medicare beneficiaries have for a few years now had access to some of their Medicare claims via Blue Button functionality; but that that data has been in raw form, without any contexting that could make it truly useful for Medicare patients. Blue Button 2.0, she promised, will facilitate that needed contexting. “Currently,” she said, “we give our beneficiaries this data in Excel or PDF formats, without any help in helping them to understand the context of it. That’s useless if that’s hard to understand.”

In an ONC press availability on Wednesday, Donald Rucker, M.D., National Coordinator for Health IT, told assembled journalists that the idea that patients aren’t ready to understand their data is “nonsense.” But when Healthcare Informatics Managing Editor Rajiv Leventhal asked UPMC chief innovation officer Rasu Shrestha, M.D., about that point, Shrestha told him that, while patient empowerment is a nice phrase, and patients are certainly more engaged than ever before, “We need some more substance behind it.” Shrestha added, “You can’t just ‘free the data’ and say, Patient X, here is your data, because they might not know what to do with it. So we need to make sure we empower the patients, but also empower them by giving them the right set of tools, insights and guidance.”

Shrestha, who is also the executive vice president at UPMC Enterprises, said part of the solution is to “shift from paternalistic medicine to intelligent, active participatory medicine, and it’s not just about the doctor-patient relationship, but about the care collaborative, where the patient is leaning in, empowered, and engaged, and you have the entire care team working to improve outcomes and better satisfaction.” That, said Shrestha, is the whole paradigm behind value-based care.

Federal regulations—a stumbling block?

And I myself asked Dr. Rucker, at yesterday’s press availability, about the potential need to rework some federal regulations, in order to allow for data to flow more freely between and among health insurers, providers, and other entities, and publicly, around such areas as pricing and outcomes. Rucker and his fellow federal healthcare officials have been stressing over and over the idea that facilitating the creation of open APIs (application programming interfaces) would somehow liberate vast troves of information. But when I asked Dr. Rucker whether some elements of antitrust law might need to be changed as part of this broad move forward, he said, “There are some things on the Stark law,” referring to the federal self-referral laws; “I’ve heard that argument. I’m not personally convinced that that is a true factor. I’m not a lawyer, but I don’t believe that that will be a significant factor in the swirl of complexity that we’re talking about. What is correct legally is that some of these population-level things are all currently covered by HIPAA [the federal Health Insurance Portability and Accountability Act of 1996], and it requires a legal HIPAA contract to do. So how is that different from what’s going on now?” he said, referring to data-sharing considerations.

The question in mind is, however, broader. There is an entire level here involving not just data and information, but how the purchasers, payers, providers, and consumers of healthcare interact, and might interact going into the future—including with regard to sharing data and information among themselves to make business decisions affecting healthcare consumers. Will the current policy, payment, insurance coverage, and consumer landscape of healthcare in the United States be one that, with the tweaks proposed by federal healthcare officials this week, provide enough of a platform for profound, consumer-led change? And for payers and providers to also be “liberated” to make needed changes in how they operate…???

With regard to that, Verma had tweeted this just before she spoke at HIMSS on Tuesday: “The days of finding creative ways to trap patients in health systems is over. It is not acceptable to prevent patients and their doctors from seeing patients' health records outside of a particular health system #MyHealthEData #HIMSS18” But there is a complexity in how the healthcare system operates, that that tweet, and some of the thoughts underlying it, appear to not fully acknowledge.

And, with regard to the question of how actual healthcare system might be compelled forward into transformational change, the honest answer is that no one knows. And while much of what Verma and Azar said this week contained substance on which most people in healthcare could agree on, at least in principle (certainly, no one is advocating for consumer disempowerment!), whether or not what they’ve proposed, awaits the test of time—and of federal healthcare officials’ intentions and execution on those intentions.

One thing is clear: Seema Verma, at least, has made it clear that she wants to push forward the idea of data-empowered healthcare consumers forcing the U.S. healthcare system to transform itself towards improved care delivery quality, cost-effectiveness, and consumer responsiveness. And, in that, as the very old saying goes, the proof will most definitely be in the pudding.




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CMS Announces 1,300 Participants for New BPCI Advanced Initiative

October 10, 2018
by Rajiv Leventhal, Managing Editor
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The new bundled payment initiative is voluntary, will qualify as an A-APM, and builds on the original BPCI model that ended in September. However, CMS has admitted that the first initiative did lose Medicare money

The Centers for Medicare & Medicaid Services (CMS) has announced that nearly 1,300 hospitals and physician group practices have signed agreements with the federal agency to participate in the Administration’s Bundled Payments for Care Improvement—Advanced (BPCI Advanced) model.

The participating entities will receive bundled payments for certain episodes of care as an alternative to fee-for-service payments that reward only the volume of care delivered.

According to CMS, the model participants include 832 acute care hospitals and 715 physician group practices—a total of 1,547 Medicare providers and suppliers, located in 49 states plus Washington, D.C. and Puerto Rico.  Of note, BPCI Advanced qualifies as an Advanced Alternative Payment Model (Advanced APM) under MACRA, so participating providers can be exempted from the reporting requirements associated with the Merit-Based Incentive Payment System (MIPS).

BPCI Advanced will initially include 32 bundled clinical episodes—29 inpatient and three outpatient.  Currently, the top three clinical episodes selected by participants are: major joint replacement of the lower extremity, congestive heart failure, and sepsis, according to CMS.

Back in January, CMS announced the launch of the voluntary BPCI Advanced model, noting that it “builds on the earlier success of bundled payment models and is an important step in the move away from fee-for-service and towards paying for value.” CMS Administrator Seema Verma stated yesterday in the announcement of the model’s participants that “To accelerate the value-based transformation of America’s healthcare system, we must offer a range of new payment models so providers can choose the approach that works best for them.”

Verma added, “The Bundled Payments for Care Improvement – Advanced model was the Trump Administration’s first Advanced Alternative Payment Model, and today we are proud to announce robust participation.  We look forward to launching additional models that will provide an off-ramp to the inefficient fee-for-service system and improve quality and reduce costs for our beneficiaries.”

Last year, CMS officially finalized a rule that cancelled mandatory hip fracture and cardiac bundled payment models. Verma has said in the past that she doesn’t think bundled payment models should be mandatory, a sentiment that some industry experts wholeheartedly agree with.

In contrast to the traditional fee-for-service payment system, in this new episode payment model, participants can earn an additional payment if all expenditures for a beneficiary’s episode of care are less than a spending target, which factors in measures of quality. Conversely, if the expenditures exceed the target price, the participant must repay money to Medicare.

How Did BPCI Fare?

The original BPCI initiative ended on September 30, and BPCI Advanced picks up where it left off, starting on October 1, and running through the end of 2023. This prior initiative included three models that tested whether linking payments for all providers that furnish Medicare-covered items and services during an episode of care related to an inpatient hospitalization can reduce Medicare expenditures while maintaining or improving quality of care. Model 2 episodes begin with a hospital admission and extend for up to 90 days; Model 3 episodes begin with the initiation of post-acute care following a hospital admission and extend for up to 90 days; and Model 4 episodes begin with a hospital admission and continue for 30 days.

According to CMS, the evaluation from these models revealed that BPCI Models 2 and 3 reduced Medicare fee-for-service payments for the majority of clinical episodes evaluated while maintaining the quality of care for Medicare beneficiaries. It also should be noted that spanning over the two years that participants were able to join the risk-bearing phase of the initiative, 22 percent of Model 2 participants, 33 percent of Model 3, and 78 percent of Model 4 participants ended up withdrawing. Most BPCI participants were in eithers Model 2 or 3; in 2017, just five hospitals belonged in Model 4, in which Medicare makes a prospective payment for the episode.

CMS noted in its report of the BPCI initiative, “Despite these encouraging results, Medicare experienced net losses under BPCI after taking into account reconciliation payments to participants.  Technical implementation issues, including the specification of appropriate target prices, contributed to these net losses. We are optimistic that Medicare will achieve net savings under a new episode- based Advanced Alternative Payment Model, BPCI Advanced, because it addresses the challenges BPCI experienced.”

To this point, a report from the Lewin Group, a healthcare consulting firm, found that in the most popular track of BPCI, Model 2, Medicare lost more than $200 million ($268 per episode) from 2013 to 2016. In Model 3, Medicare lost slightly more than $85 million ($921 per episode) over that same time period, according to the report.

Moving toward BPCI Advanced, the federal agency points out some key differences between the original model and the new one, such as:

  • BPCI Advanced offers bundled payments for additional clinical episodes beyond those that were included in BPCI, including, for the first time, outpatient episodes.
  • BPCI Advanced provides participants with preliminary target prices before the start of each model year to allow for more effective planning. The target prices are the amount CMS will pay for episodes of care under the model.
  • BPCI Advanced qualifies as an Advanced APM and is eligible to earn the 5-percent bonus in the Quality Payment Program.

Keely Macmillan, the general manager of BPCI Advanced for Archway Health, a Massachusetts-based company that helps providers get started in bundled payment programs, says she is happy with the level of participation so far. She did add that one thing her company noticed immediately, regarding the participant list, was the popularity of joint replacements and cardiac bundles. “Research coming out in the last few months has proven that these bundles do particularly well, and we’re excited to help our participants and see others industrywide continue to drive improvement in the new program,” she says.

Meanwhile, Clay Richards, president and CEO of naviHealth, a post-acute care management company based in Tennessee, and which is a BPCI convener, notes that its hospital and health system partners saved more than 8 percent, or approximately $2,000 per episode, which translates to more than $83 million in the BPCI initiative. “With the increase in BPCI Advanced participation, we expect the impact to be even greater,” says Richards.

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On the Road to Risk, Summit Medical Group is Driving in the Fast Lane

October 2, 2018
by Rajiv Leventhal, Managing Editor
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Dr, Jeffrey Le Benger, M.D., CEO of Summit Health Management and Summit Medical Group, discusses how his organization is succeeding in a mostly value-based care environment

At Summit Medical Group (SMG), the oldest independent multispecialty physician group in New Jersey, Jeffrey Le Benger, M.D., has been providing high-level leadership for 16 years. With more than 800 providers at 70 locations, multiple comprehensive ambulatory care campuses and a strategic partnership with MD Anderson Cancer Center, SMG handles more than 1.5 million patient visits annually. Its officials believe that its performance is marked by a sustained enhancement to clinical quality and patient outcomes, ongoing participation in emerging value-based reimbursement initiatives and meaningful cost containment.

Indeed, after devising and refining a highly effective practice management and patient care model at SMG and extensively studying the condition of mid-range and large-scale independent physician groups nationwide, Dr. Le Benger spearheaded the formation of Summit Health Management (SHM) in 2014 to share SMG’s formula for success via strategic partnerships and customized managed services contracts. Now, Le Benger serves as chairman of the board and CEO of Summit Health Management and Summit Medical Group.

SHM is now poised to become a national organization, with the aim to positively impact the delivery of patient care across the country, as Le Benger envisioned, with the 2017 establishment of a major agreement with the Bend Memorial Clinic in Oregon and an alliance with Arizona Primary Care Physicians (APC) that resulted in the formation of Summit Medical Group Arizona. 

In a recent interview with Healthcare Informatics, Le Benger outlined the progress and evolution of his organization and how it is continuing to plunge ahead into the world of risk and value-based care. Below are excerpts from that discussion.

How is your organization progressing when it comes to taking on risk for your patients?

We are at a point in which 65 percent of our patient base is based within risk-based contracting, and it’s a continuum, so you have fee-for-service and then percent to premium is on the other side. And then there are all aspects of risk in in between; there is pay-to-play, shared savings, and full risk. Most of our contracts that have upside and downside risk have a shared savings component. But as soon as we increase the size of our attribution and can mitigate our risk more evenly, then we will look to go to percent to premium as a group.

Jeffrey Le Benger, M.D.

Can you detail the ACO (accountable care organization) work that you’re involved in?

We are a part of the Trinity Health ACO [which serves patients in Illinois, Michigan, New Jersey and Ohio], and are in the Centers for Medicare & Medicaid Services (CMS)’ Next Generation ACO Model. Over the past two years we have received shared savings and we do take on upside and downside risk. The issue with Next Gen is that you are benchmarked against yourself [rather than against outside ACOs], so you have to improve [internally] every year. In Medicare Advantage, you are benchmarked against the community that you have the product within. So the house always wins. The government knows that shared savings pushes the envelope, but the cost to create that savings far outweighs the savings they get in a trend demonstration.

What are your thoughts on the recent CMS proposed rule for ACOs? Do you think it’s too aggressive or fair?

We are a large group of [nearly] 900 providers that is fully integrated and not consolidated, so pushing into risk is not an issue. We are already capable of handling more risk in the organization. But when you have a consolidated network, or an individual doctor or smaller group, the amount of data analytics that’s needed to manage risk is financially unaffordable. For a hospital institution, I think you will find that they will have a hard time on the payment schedule as they move towards risk on fair market value. So the small practices will have to figure out how they will consolidate into a larger group to help defray some of their costs for the data analytics they need to do in order to take on risk.

How are you currently handing MACRA/MIPS?

We are in an advanced alternative payment model (A-APM) since we are in Next Gen, though we still have physicians who come on that are required to do MIPS. For us, we have the data analytics to handle it and we have achieved a fair amount of savings in MIPS. Now they are moving to bundling programs, so we can manage that with the data analytics that we have. The government has demonstrations to see what makes sense and what doesn’t, and then you have all these practices figuring out how they could justify moving in and out of all the programs, and where the best economic value is. And it doesn’t mean you will have the best quality outcomes, but rather you are looking to move to the program where you see the best economic value.

How are things progressing with Summit Health Management?

[In 2014], we broke out all of management from Summit Medical Group and we started Summit Health Management. It started with 500 employees, and we have full coding compliance, we audit within it, as well as having all revenue cycle, accounting, and MSO (managed service organization) services within it. Also within it is a large population health department that we offer services to the three groups that we have MSA agreements with: Summit Medical Group New Jersey, Summit Medical Group Oregon, and Summit Medical Group Arizona. So we can scale the commitment and the resources within the management company to the three groups in order to run what is needed in that organization for its value proposition.

Each location is different, so we are ahead of the curve with upside and downside risk in New Jersey, with 65 percent of our population at full risk. In Oregon, it’s a little bit of shared savings and a little pay-to-play, and in Phoenix, besides the MSSP (Medicare Shared Savings Program) product and managed Medicare, on the commercial side it’s only a little pay-to-play. So we are able to adjust and scale what’s needed in the different organizations in the management company.

What are the keys to having 65 percent of your patient population in New Jersey at full risk?

It has to do with the governance and leadership of the organization, and how we structured the culture as an all-for-one. We also don’t differentiate in how the doctor sees a patient from the PPO world versus the HMO world. In all of our products, we heavily manage the sickest percent of the patient population, and we decentralize preventative care in the organization. We see it as “payer-blind” in terms of how we compensate within the organization. So they do not know who is a fee-for-service patient and who is an HMO patient because we don’t want to make a distinction on how they care for the patient. And that was culturally how it was developed in the group.

And on the back end, yes, sometimes we do a little more care management for one [side] or the other because it’s [needed], but we do try to manage all patients the same way. We know that all of our payers will eventually move to higher risk, so when you are in the fee-for-service world, these payers know what the total cost is because claims adjudication is still based in a fee-for-service world.

[Essentially], you are still putting in individual claims, but you are rolling up all those costs and then comparing it to your total costs to the total costs on the outside. If you cannot demonstrate savings to a payer, even in a fee-for-service world, they will go after your rate structure, and you essentially will be at risk because you will lose revenue if they decrease your reimbursement in that program.

How important are payer-provider relationships? Have they improved in recent years?

You cannot look at your payer relationships as adversarial when you are in a large group practice. Think of them as your partners, because as all insurers move to high-deductible or employer-based [plans], you have to look at how you achieve savings moving forward. When you look at shared savings, who is benefitting in the shared savings? It has to either be either the employer, the insurance company, the beneficiary, or the provider.

We are in a full-risk contract with Horizon Blue Cross Blue Shield in New Jersey, and they are a very good partner. We have more than 60,000 attributed lives who are at full risk with Horizon in the state, and we have seen that we have lowered the cost of care with this product over the past five years, and we have consistently beat the market in lowering the cost of care. So the payer is happy, the employer base is happy and the individual, who might not realize it, is happy because we look at the sites of service and we lowered the out-of-network or deductible cost for that patient.

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What to Expect Next from CMS Regarding the Proposed ACO Rule

October 1, 2018
by Lynn Barr, Industry Voice, CEO and Founder, Caravan Health
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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 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 or call us at (916) 542-4582.

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