The Centers for Medicare & Medicaid Services’ long-awaited proposed changes to the Medicare Shared Savings Program are designed to usher in a new phase of the program beginning in 2020. The changes would require that all MSSP accountable care organizations be held accountable for both the cost and quality of care.
The biggest proposed change to the program would require MSSP ACOs to bear risk. It is estimated that the changes will result in more than $2 billion in savings by 2028.
The proposed changes include:
- The creation of two performance tracks: Basic and Enhanced
- Under the Basic track, participants will only share in savings for up to two years. By year three, all Basic MSSPs will be required to bear some risk. The Basic track will replace the existing Track 1 and Track 2.
- Participants of the Enhanced track will bear risk immediately. The Enhanced MSSP track will be considered an advanced Alternative Payment Model. Track 3 MSSP will be renamed the Enhanced track.
- MSSP ACOs will sign a five-year contract, as opposed to the current three-year contract.
- CMS requires participating ACOs to pay any losses incurred, even if the MSSP chooses to withdraw from the program mid-year.
- Poorly performing ACOs may be cut from the program.
This raises the question: What will the MSSP look like in the 2019 performance year? As of now, new MSSPs will apply to join the program in July 2019. The 203 MSSPs that are currently up for renewal, based on launch year, can apply for a six-month extension beginning in January 2019. These ACOs will then apply to renew participation for the July 2019 start date.
These MSSP developments will likely have significant impact on participation in the program. It’s possible that the proposed changes, coupled with the delayed start date for 2019, could reduce interest in Medicare ACOs. ACO participants have shown reluctance to bear risk, and it has been reported that 70 percent of MSSPs would leave the program if forced to bear risk. While the proposed changes are logical steps in the industry’s pursuit of fee-for-value, they may test the limits of how far providers are willing to be pushed in order to reign in healthcare costs.
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