An organization interested in participating in the Medicare Shared Savings Program (MSSP) as an accountable care organization (ACO) must file a non-binding Notice of Intent to Apply (NOIA) by 12 Noon EDT on Wednesday, May 31, 2017. Only those organizations that file a NOIA will be permitted to file an MSSP application, which will be due by 12 Noon EDT on Monday, July 31, 2017.
The NOIA must be submitted electronically. Detailed instructions are available in the Centers for Medicare & Medicaid (CMS) NOIA Guidance Document. Keep in mind the NOIA is non-binding; there is no prejudice to an organization that submits an NOI, but later elects not to file an MSSP application. Nor is there any prejudice to 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. We anticipate a bumper crop of MSSP ACOs this year, as the program has gone from cutting edge to mainstream. Also, with 2017 as the first performance year under the new Merit-Based Incentive Payment System (MIPS), physicians now are seeing the advantages of MSSP participation vis-à-vis MIPS.
A physician participating in a Track 1 MSSP ACO (no downside risk) will not be required to report separately on the MIPS quality and improvement activities components. Instead, CMS will convert the ACO’s overall performance into a MIPS composite score for participating physicians. For a much more detailed explanation, please see our earlier blog post on the APM Scoring Standard. A physician participating in a Track 1+, Track 2, or Track 3 MSSP ACO (each of which involves some downside risk) will be exempt from MIPS, and instead will receive a 5% bonus payment on Medicare Physician Fee Schedule Payments.
PYA has assisted numerous now-successful MSSP ACOs in evaluating the opportunity, filing the NOIA, preparing and submitting an MSSP application, and establishing ongoing operations. For more information, contact Martie Ross or David McMillan, (800) 270-9629.