CMS remains fully committed to the transition to value-based care and Accountable Care Organizations (ACOs) are a big part of this strategy. As a result, CMS is enacting measures to support Medicare Shared Savings Program (MSSP) ACOs during the COVID-19 pandemic. ACOs are groups of doctors, hospitals, and other health care providers, who come together voluntarily to give coordinated, high-quality care to their Medicare patients. The goal of coordinated care is to ensure that patients get the right care at the right time, while avoiding unnecessary duplication of services and preventing medical errors.
Roughly one third of 517 MSSP ACOs are participating in two-sided, shared savings and shared losses models in 2020. The COVID-19 Public Health Emergency (PHE) has created significant uncertainty around the potential costs for caring for patients impacted by the pandemic. As a result, the government has officially invoked the MSSP’s Extreme and Uncontrollable Circumstances Policy.
In order to protect ACOs from being unduly harmed by the extraordinary circumstances surrounding the PHE, CMS is making the following changes:
- Calculation of Shared Losses: The Extreme and Uncontrollable Circumstances Policy of the COVID-19 pandemic began in January 2020 and will apply for the duration of the PHE. Shared losses will be mitigated for all ACOs participating in the two-sided, shared risk models. The level of mitigation will be proportionate to the length of time the PHE is in effect. For example, if the PHE extends until July 1st, then any shared losses an ACO incurs for performance in the year 2020 will be reduced by fifty percent. If the PHE covers the full year (January through December 2020) any shared losses an ACO incurs for performance in the year 2020 would be reduced completely, and the ACO would not owe anything.
- Quality Reporting: The 2019 quality reporting period for ACOs was extended for an additional 30 days until April 30, 2020. If the ACO is unable to complete their Quality Reporting by the deadline, they will receive the mean score for all ACOs. ACOs that do complete their reporting will receive the higher of their own performance score, or the ACO mean score.
- Participation in the Shared Savings Program:
- CMS is forgoing the application cycle in 2020 for agreements starting January 1, 2021 and will offer a voluntary 1-year agreement extension for ACOs whose agreements end on December 31, 2020.
- BASIC track ACOs participating in the glide path towards increased risk will have the option to forgo their first automatic advancement into increased levels of risk and potential reward.
- Financial Methodology: To avoid rewarding or penalizing ACOs for having higher/lower COVID-19 spread in their assigned beneficiary populations, CMS is removing all Parts A and B payment amounts for episodes of care for treatment of COVID-19 for determination of benchmark year and performance year expenditures.
- Telehealth and Beneficiary Assignment: CMS is appreciating that ACOs are using telehealth visits at significantly higher levels during the PHE. As a result, CMS is including additional telehealth codes within the definition of primary care services used in determining beneficiary assignment.
CMS has made multiple policy changes to support healthcare providers during the PHE on the Fee-for-Service side. These recent changes to the ACO model offer welcomed support to MSSP participants and will go a long way to ensuring the long-term viability of ACOs.
