Once a year, the Centers for Medicare & Medicaid Services (CMS) accepts applications for participation in the Medicare Shared Savings Program (MSSP). On March 22, CMS announced the deadlines for the 2018 application cycle.
An organization interested in participating in the MSSP as an accountable care organization (ACO) effective January 1, 2018, must file a non-binding notice of intent (NOI) by 12 noon EDT Wednesday, May 31. Only those organizations that file an NOI will be permitted to file an MSSP application, which will be due by 12 noon EDT Monday, July 31. Applicants then will have until 12 noon EDT Wednesday, August 30 to submit their final ACO participant lists.
The NOI must be submitted electronically. Detailed instructions soon will be available on the CMS MSSP website. However, one can now review the instructions from the 2017 application cycle to become familiar with the process CMS previously used.
Keep in mind the NOI is non-binding; there is no prejudice toward an organization that submits an NOI, but later elects not to file an MSSP application. Nor is there any prejudice toward an organization that files an MSSP application, but later elects not to sign a Participation Agreement.
Since the program’s inception in 2012, the number of MSSP ACOs has grown by approximately 100 each year. Today, 480 organizations across the nation are part of the program, serving over 9-million Medicare beneficiaries. Once considered a “bleeding edge” strategy, the formation and operation of ACOs has become mainstream.
We anticipate a bumper crop of MSSP ACOs this year, as we are seeing many organizations that previously passed up participation now taking a close second look at the opportunity. Here are a dozen reasons for organizations that have been sitting on the fence to consider jumping into the MSSP arena as Track 1 ACOs:
- The MSSP provides structure and discipline for new or near-new provider networks (governance structure, timelines, terms of participant agreements, performance measures).
- There is no downside risk associated with participating in the MSSP as a Track 1 ACO— only the opportunity to earn shared savings. Presently, 438 of the 480 MSSP ACOs participate in Track 1 ACO— only the opportunity to earn shared savings. Presently, 438 of the 480 MSSP ACOs participate in Track 1.
- Physicians participating in an MSSP ACO are not required to report separately on MIPS performance measures. Instead, CMS converts the ACO’s performance on the required MSSP quality measures into a MIPS composite score for participating physicians.
- An MSSP ACO receives access to Medicare claims data for its attributed beneficiaries, giving participants the information needed to more efficiently manage those beneficiaries’ care.
- MSSP ACOs have the opportunity to utilize fraud and abuse waivers to protect those activities consistent with the underlying purposes of the MSSP.
- MSSP ACOs have consistently demonstrated improvement in quality of care and patient satisfaction scores.
- Although less than one-half of MSSP ACOs have earned shared savings, those participating in the program for more than one year are more likely to be successful in this regard.
- Commercial payers (including Medicare Advantage plans) and employers view MSSP participation as legitimizing a provider network for contracting purposes.
- For hospitals and health systems, the MSSP offers a low-risk, low-cost vehicle for physician alignment to pursue hospital priorities (e.g., reduction in readmissions and hospital-acquired infections) and gainsharing opportunities.
- Research shows participation in upside-only arrangements can often create a sufficient incentive for physicians to change their behaviors to achieve cost savings and improved scores on performance measures.
- CMS provides MSSP ACOs with multiple peer learning opportunities related to population health management strategies (e.g., publications and events).
- With the growth of the MSSP across the nation, program participation is now becoming a defensive strategy. If the local hospital or health system does not provide community physicians with an opportunity to participate in the MSSP, it is becoming more likely someone else will.
Over the last five years, PYA has assisted numerous now-successful MSSP ACOs in evaluating the opportunity, recruiting participants, developing their governance structure, filing the NOI, preparing and submitting an MSSP application, and establishing ongoing operations. For more information, contact Martie Ross or David McMillan, (800) 270-9629.