Rural providers have until May 29 to submit a non-binding notice of intent to participate in the Medicare Shared Savings Program (MSSP) and to apply for funding through the ACO Investment Model (AIM) Program.
This year, the Center for Medicare and Medicaid Innovation (CCMI), part of the Centers for Medicare & Medicaid Services (CMS), is making available more than $100 million to help rural ACOs participating in the MSSP develop operational infrastructure. These ACOs are eligible for $1.4 to $2.5 million in advance payments, depending on the number of Medicare beneficiaries attributed to the ACO. This money may be used, for example, to acquire needed technology and support services and hire care coordination staff.
To be accepted into the MSSP – and thus be eligible for AIM funding – a rural ACO must have at least 5,000 and no more than 10,000 attributed Medicare beneficiaries. On their own, most rural communities cannot reach this threshold. Two or more communities partnering together, however, can meet this requirement.
The first step in such a partnership is forming the ACO as a new legal entity. CMS regulations require that multiple taxpayer identification numbers (TINs) coming together to form an ACO must create a new legal entity for that purpose. This is a relatively simple process, requiring the filing of a one- or two-page article of incorporation or organization with the Secretary of State, and securing a TIN by completing IRS’ on-line form. This work usually can be completed in a day or two.
Once the ACO entity is formed and has a TIN, the next step is to submit the non-binding notice of intent with CMS by no later than May 29. Again, this is a relatively simple process: it is an on-line form that takes only a few minutes to complete.
Next, the ACO entity will need to get to work on completing the MSSP application, which is due July 31. This is not a simple process, as it requires detailed information on how the ACO intends to operate if accepted into the program. Also, the ACO must secure signed participation agreements from each entity that will be part of the ACO in advance of submitting the application. (To learn more about the MSSP application process, please see PYA’s ACO Road Map. It provides a complete summary of the regulatory requirements.)
Because Medicare beneficiaries are attributed to an ACO based on the physician who provides the “plurality” of primary care services to a beneficiary, an ACO must recruit a sufficient number of primary care physicians as participants. This means a hospital must communicate with its medical staff regarding the opportunity presented by the MSSP and the AIM Program.
CMMI has not yet released the AIM Program application or the timeline for submission of that application, but we expect it will be concurrent with the MSSP application process. We do know the application will require a detailed spend plan for the funds received through the program. The spend plan must be unique to the ACO and identify and address local needs.
Keep in mind the AIM Program funds are not free money. CMS will withhold any shared savings earned by the ACO until the full amount has been repaid. If an ACO elects to leave the MSSP before the end of the three-year performance period, the ACO must repay any amount still owed to CMS. However, if the ACO completes the performance period and exits the program, any remaining amount owed will be forgiven.
The AIM Program offers a real opportunity for rural providers to collaborate with neighboring communities to develop sustainable infrastructure for new payment and delivery systems. The competencies developed through active participation in new care payment models, such as ACOs, are key to success in population health management and value-based reimbursement.
PYA is supporting several rural communities as they organize to pursue the MSSP and AIM Program. Our deep knowledge of rural health issues and experience with the MSSP and CMMI application processes allow us to be effective partners in this process. To discuss opportunities for your community, please contact Martie Ross (mross@pyapc.com.
