Aco proposed rule pdf

Final rule on the pathways to success medicare aco. If an aco elects this option, it will transition directly to level e for the remaining two performance years of the agreement period. This is a link to the 2020 quality payment program qpp proposed rule that is published on the federal register. Medicare shared savings program mssp aco tracks to the aco tracks in the final rule. Hastings post offers a first look at the rules legal structure, governance, and regulatory sections. Appendix proposed rule versus final rule for accountable care. We also finalized provisions to streamline the aco core.

There is risk inherent in the proposed aco structure. Medicare shared savings program final rule american hospital. This paper describes how the impact of the rule change will vary by aco depending on its current situation and unique characteristics and examines the rule from the perspective of different aco situations. Executive summary notice of proposed rulemaking for the. This proposed rule would implement section 3022 of the affordable care act which contains provisions relating to medicare payments to providers of services and suppliers participating in accountable care organizations acos. Final rule timeline proposed rule published in aug. Summary of major issues addressed in the medicare shared savings program proposed rule background the medicare shared savings program mssp now includes more than 330 acos and more than 125,000 medicare enrolled practitioners. Mssp proposed rule seeks to enhance aco transparency and. As part of the administrations broader myhealthedata initiative, this proposed rule promotes interoperability and patient control of their medical data by proposing a new requirement around aco adoption of the 2015 edition of certified ehr technology cehrt. July 1, 2019 and subsequent performance years, for eligible acos applying for, or currently approved for, a snf 3day rule waiver.

Category final rule summary change from proposed rule. The final rule should note that home health provides the ideal, existing organizational infrastructure to immediately help establish an acos capabilities, reach medicare beneficiaries in their home settings and collaborate with and assist other care providers to facilitate and ensure the success of the aco program. On balance, the proposed rule represents a major advance for the mssp, and the commission. In view of the complexity of the accountable care organization aco program and the demands on your staffs time, we appreciate the efforts you are taking to improve the program. The aamc represents is a notforprofit association representing. Rule changes cms has made are intended to create a more balanced way of determining when accountable care organizations earn shared savings incentives. Apic is a nonprofit, multidisciplinary, international organization representing over 14,000 infection preventionists ips, whose mission is to. This notification must be provided in the form of a widespread, clear communication to acos about the quality measure specification changes through multiple communications such as publication in the aco spotlight newsletter, updates in the aco ms, etc. Cap is a national medical specialty society representing more than 17,000 physicians who practice anatomic andor clinical pathology. Acos eligible for the basic tracks glide path that are new to the program would have the flexibility to enter the glide path at any one of the five levels. The proposed rule would also provide for limited waivers of the originating site and geographic requirements to allow for payment for otherwise covered telehealth services provided to beneficiaries who are no longer prospectively assigned to an applicable aco and therefore no longer eligible for payment for these services under section 1899l.

The members of the alliance appreciate the secretarys, administrators and cmss efforts to fulfill the affordable care act and to identify innovative. Produced by the aco learning network at the brookings institution. Naacos disagrees with cmss comments that acos do not generate savings and we are pushing back on these claims. Proposed changes to the medicare shared savings program for. Cms proposed rule describes aco quality performance standards. The rule proposes major changes to the medicare shared savings program mssp. First, the proposed rule from cms was very clear that the current aco model was focused on primary care and was not focused on specialist care. Under the proposed rule, aco participants will continue to bill the medicare program for their feeforservice payments as they do currently.

However, the proposed rule does not appear to recognize a the important role that independent laboratories currently play in improving the quality and coordination of patient care and could play in accountable care organizations acos, or b the impact of. Accordingly, while there may ultimately be a role for more renalspecific care models, we felt it was important to deal directly with the issues raised by the current proposed rule. Under the proposed rule, should an acos assigned population fall below 5,000 during the course of the agreement period, cms would issue a warning and place the aco on a corrective action plan. Acos under revised policies laid out in a proposed rule. The final rule allows lowrevenue acos without prior aco experience three years on the basic track under an upsideonly agreement. By electronic delivery marilyn tavenner administrator.

An aco must demonstrate that it meets patientcenteredness criteria specified by the hhs secretary, such as the use of patient and caregiver assessments or the use of individualized care plans. The rule changes give acos more potential to receive incentives for this progress as cms seeks to support growth of the organizations. Notice of proposed rulemaking for the medicare shared savings program. An aco would have an incentive to improve the quality of care for medicare patients seen by its participating providers and suppliers. Accountable care organizations acos 101 what is an aco. This is a proposed rule and we could see significant changes in a final rule the proposed policies affect acos differently, depending on many characteristics of the aco ex. November 2018 final rule, we finalized certain policies from the august 2018 proposed rule in order to ensure continuity of participation, and finalize timesensitive program policy changes for currently participating acos. Proposed medicare shared savings aco program rules the centers for medicare and medicaid services cms and other affected agencies released their notice of proposed rulemakingrequest for comment for the medicare shared savings program program on march 31, 2011. To improve accuracy, cms should remove an acos own beneficiaries from the regional. Legal structure, governance, and regulatory sections. Qualifying acos will, according to the proposed rule, be required to have a fairly comprehensive compliance plan in place to address how the aco will comply with all legal requirements.

Department of health and human services centers for medicare. Cms proposes pathways to success, an overhaul of medicares. We recognize the importance of the goals of aco initiatives as they seek to improve both the. Yet, the proposed rule doubles down on acos and proposes many alterations to the existing aco program that concern the cpr coalition, particularly in the area of postacute care.

Stakeholder comments will help shape the future direction of the program by s. Medicaid services request for comments on the proposed rule for accountable care organizations acos as part of the medicare shared savings program. The aco would remain eligible for shared savings over the course of the performance year for which the warning was issued. Cms issued a final rule addressing changes to the medicare shared. Advamed has been a strong supporter of acos since their inception in the affordable care act. Although the program seeks to begin transforming the current feefor. Currently, 82% of acos participating in the medicare. Advamed has been a strong supporter of accountable care organizations acos since their inclusion in the affordable care act. The proposed rules are designed to promote coordinated patient care and foster improved quality, better health outcomes, and improved efficiency. The proposed rule calls for medicare to take a retrospective look at the beneficiarys use of services to determine whether a particular aco should be credited with improving care and reducing expenditures. Acos continue to be a grand, national experiment that has not yet been validated as effectively achieving its stated goals. In august 2017, cms released a proposed rule pdf that would shrink the amount of time acos can be in an upsideonly model to two years. Importantly, the 2019 mssp application process has been delayed as a result of this nprm.

Medicare payments will be made directly to the aco participant, not to the aco, based on the claims and services each aco participant provides. American college of physicians medicare shared savingsaccountable care organization aco final rule summary analysis category final rule summary change from proposed rule and comments definition of aco general concept aco refers to a group of physician and other healthcare providers and suppliers of services e. In contrast, acos expressed support for a number of proposals in the rule and the top three opportunities were clear with the first, selected by over 55 percent of respondents, being the ability to choose an assignment. This would help acos better assess the quality of care provided by the aco s ai physician participants and providersuppliers. The proposed safe harbors also include multiple proposed safeguards to protect against fraud and abuse. In the proposed rule, cms acknowledges that it has statutory authority to exclude dsh and ime payments from its calculations of an acos benchmarks, but questions its statutory authority to exclude such payments from its calculations of actual expenditures. Proposed rule versus final rule for accountable care organizations acos. Dec 15, 2014 under the medicare shared savings program mssp aco proposed rule, cms has proposed additional program requirements, beneficiary protections and participation agreement procedures to enhance aco transparency and improve patients ability to make informed health care decisions. Proposed pathways to success for the medicare shared.

Provisions of the proposed rule, summary of and responses. In the proposed rule, cms acknowledges that it has statutory authority to exclude dsh and ime payments from its calculations of an aco s benchmarks, but questions its statutory authority to exclude such payments from its calculations of actual expenditures. Readers are directed to the proposed rule for a complete description of the proposals. Accountablecareorganizationmodelopportunityfactsheet. Under the proposed rule, should an aco s assigned population fall below 5,000 during the course of the agreement period, cms would issue a warning and place the aco on a corrective action plan. Under the proposed rule, aco participant pharmacists should already be eligible for aco participation and shared savings related to the provision of dsmt services because those services are provided under part b ffs. Under the proposed rule, an aco that meets the programs quality performance standards would. In march, cms issued an aco proposed rule outlining its vision for the program and solicited public comment. The proposed rule would also hold acos accountable for downside risk by requiring acos to repay. Cms will forego a january 1, 2019 start date for new and renewing acos, and instead proposes a july 1, 2019 start date for acos. Some of the key changes included in the final rule include. Availability of the snf 3day rule waiver for eligible acos under performancebased risk under either prospective assignment or preliminary prospective assignment. Centers for medicare and medicaid services department of.

For example, new high revenue acos would be required to. Summary of major issues addressed in the medicare shared. Assess the potential impact of the changes on your medicare aco participation. Claims data shared only for patients the aco may contact beneficiaries. Proposed changes to the medicare shared savings program. Summary of proposed rule provisions for accountable care. Mssp acos pathways to success final rule timeline proposed rule published in aug. Results for 2015 aco performance will be released later this. Cms proposed rule for the medicare shared savings program acos comments due 60 days from the date of publication june 6, 2011 joint cms and oig proposed rule on waiver designs addressing proposed. Aiming to coordinate care, aco proposed rule falls short inside. The aco would remain eligible for shared savings over the course. Department of health and human services centers for. Cap members practice their specialty in clinical laboratories, academic medical.

And care coordination is a core competency for the nursing profession. The proposed rule makes a number of proposed changes including the addition of a track 3 option for acos that would like to assume increased levels of twosided financial risk. Related to the medicare shared savings program four documents released on march 31, 2011. Aiming to coordinate care, aco proposed rule falls short.

This new highlow revenue distinction determines program specifics such as the timing for when an aco must move to risk. Medicare shared savings program, aco final rule aafp. Cms pushes acos to take on more risk with medicare shared. One allows an aco to share in any savings during years one and two of the three year agreement. We propose that the participation options in the basic tracks glide path would depend on an acos experience with the shared savings program, as described in section ii. On march 31, 2011, cms released a much anticipated notice for proposed rule making, which contains proposed rules for implementing the new program. Care coordination is a building block on which much of the aco quality improvement and cost control provisions are built. In december 2018, the center for medicare and medicaid services. Ncpa supports this approach, but seeks clarity on the. Proposed changes to the medicare shared savings program for accountable care organizations. Commenter feedback on the proposed changes to the mssp. This paper summarizes the key provisions of the final rule for the 2019. Cms proposed rule for the medicare shared savings programacos comments due 60 days from the date of publication june 6, 2011 joint cms and oig proposed rule on waiver designs addressing proposed waivers of the civil monetary penalties cmp law, federal antikickback statute, and the physician selfreferral law. Cms is proposing to implement two different risk models from which an aco can choose.

Accountable care organizations office of inspector general u. Affordable care act, as well as proposed rule, federally qualified critical access hospitals paid health centers and rural health clinics through method ii, are eligible to are also eligible to both form and form an aco. Aafp letter to senate help committee on innovation november 28, 2018 3 page pdf aafp comments to cms on msspaco proposed rule october 15, 2018 25 page pdf aafp letter to congress on the. In the proposed rule, cms describes two methods for distributing potential shared savings to acos.