As a result of the public health emergency, the Centers for Medicare and Medicaid Services (CMS) is offering voluntary elections to eligible Accountable Care Organizations (ACOs) to maintain the Medicare Shared Savings Program (MSSP) BASIC track level for Performance Year 2021.
Per the joint venture of Healthcare Solutions Network (HSN), St. Elizabeth Provider Network (SEPN) and TriHealth Physician Hospital Organization (TPHO) have agreed to remain in MSSP’s, Level B – no financial risk – effective January 1, 2021 through December 31, 2021.
Previously, CMS had ruled ACOs participating in MSSP were required to advance each year to a higher stage of financial risk.
The MSSP glide path includes five levels: a one-sided model available only for the first two years to most eligible ACOs and three levels of progressively higher risk in years three through five of the agreement period. The glide path concludes with a maximum level of risk that qualifies as an Advanced APM for purposes of the Quality Payment Program.
The mechanics for traditional Medicare beneficiaries in MSSP remain as follows:
- Attribution
Beneficiaries are assigned to an ACO based on the plurality of primary care services from a PCP in the ACO during the previous years. Otherwise, if no primary care services are by a PCP (in or out of the ACO), assignment is based on where the beneficiary receives the plurality of primary care services from a specialist in the ACO.
- Quality Reporting
ACOs must report quality data to assess performance and, to share in any savings, the ACO must meet the established standards for the given performance year. MSSP participation qualifies the group as a MIPS APM, therefore, receiving an aggregate MIPS score for the ACO.
- Shared Savings/Financial Benchmarks
In order to achieve shared savings, ACO expenditures must achieve a minimum savings rate (MSR) – a set percentage by which actual expenditures are less than the ACO’s expenditure benchmark.
The MSR is calculated based on attributed beneficiaries and the benchmark will be calculated using risk-adjusted (HCC methodology) average per capita expenditures for Parts A and B for original Medicare FFS beneficiaries during the three years prior to performance.
The ACO will share in the first dollar savings beyond the MSR at a rate up to 50%.
- Claims Data
CMS will provide ACOs with information on the assigned populations and financial performance at the start of the agreement period and routinely during the course of the year. Reports include:
- Monthly claim and claim line feeds
- Assignment list reports with beneficiary information and summary info for benchmark years
- Aggregate expenditure and utilization reports for benchmark and performance years
- Historical benchmark report detailing the ACO’s three-year average per capita benchmark value
- Reconciliation reports for historical and update benchmarks and determination of savings
- Incentive Calculation and Timing
The final amount of shared savings is determined by 1) determining whether actual expenditures are below the expenditure benchmark and verifying the MSR has met or exceeded and 2) adjusting the amount of savings by qualify measure performance