The National Association of ACOs and America's Physician Groups are telling the Centers for Medicare and Medicaid Services that its application deadline to apply for the revamped Shared Savings ACO program does not give providers enough time to consider the new rule that was only finalized on December 21.
On Thursday, CMS set the deadline at February 19 to participate in the new Pathways to Success accountable care organization program. This is two months after the agency published a nearly 267-page rule overhauling the Medicare Shared Savings Program and only three weeks after finalizing the rule, said the National Association of ACOs.
CMS hasn't even posted all the application materials yet, the group said.
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The organization representing ACOs is calling upon CMS to push the deadline to later in March.
America's Physician Groups said that while the final rule addresses many of the challenges facing both ACOs and CMS in further advancing the value movement, it remained concerned with the short application window. The deadline does not allow ACOs the time they need to model the new options outlined in the final rule or prepare for successful participation, APG said.
The rule shortens, from six to two years, the amount of time ACOs have before being put at risk for repaying losses for not hitting pre-set spending targets.
It also lowers the financial incentive to participate in no-risk models by cutting the shared savings rate to 40 percent. It has a distinction between so-called "high revenue" and "low revenue" ACOs, forcing high revenue ACOs into risk-bearing models faster.
ACOs need more time to understand the changes and determine participation options with affiliated doctors, hospitals, and other providers, electing levels of risk or track participation, establishing repayment options, making choices about what waivers to apply for, among other choices, NAACOS said.
Quality reporting for various Medicare programs is also done in January and February. The deadline to apply for CMS's Bundled Payments for Care Improvement Advanced Model is March 1.
The application process for the Medicare Shared Savings Program opens on January 18.
CMS proposed the overhaul in August and on December 21 finalized the Pathways to Success rule.
NAACOS said it is concerned the changes will limit interest in the voluntary program, cause existing ACOs to drop out and harm Medicare's largest value-based care program. The MSSP accounts for 561 ACOs.
WHAT ELSE YOU NEED TO KNOW
The February 19 deadline applies to new ACOs, ACOs whose agreements expired Dec. 31, 2018, and ACOs which want to end their current agreements and start under the new Pathways structure.
ACOs with three-year agreements that expire at the end of 2019 or 2020 are allowed to finish those contracts before starting in the new structure.
ON THE RECORD
"ACOs barely have time to understand the new rules, and organizing an application is very complicated and for some, it is now a high-risk decision," said Clif Gaus, Sc.D., NAACOS president and CEO. "There are too many difficult decisions to rush."
"Setting an application deadline two months after publishing the final rule does not give ACOs that have expiring agreements the necessary time to vet the decision internally or the time to process the many elements of the application," said Jennifer Moore, NAACOS board member and chief operating officer at MaineHealth ACO in Portland, Maine. "Given the significant changes, ACOs need to engage actuaries to understand how we would fare in downside risk. Such an analysis takes time. Without that time, we would have to enter an upside track out of the gate."
"We believe that this short period in time does not allow ACOs the time they need to model the new options outlined in the final rule or prepare for successful participation," said Valinda Rutledge, vice president of Federal Affairs for America's Physician Groups.
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