ACO REVIVAL. Medicare Shared Savings Program Final Regulation Overview. Blue & Co., LLC Healthcare Reform Symposium Thursday, November 3, 2011

Similar documents
Accountable Care Organizations Under Medicare Shared Savings Program PROPOSED RULE

REPORT OF THE BOARD OF TRUSTEES

Request for Information Regarding Accountable Care Organizations (ACOs) and Medicare Shared Savings Programs (CMS-1345-NC)

The Accountable Care Organization & Compliance

The Accountable Care Organization & Compliance

Payment and Delivery System Reform in Vermont: 2016 and Beyond

Accountable Care Organizations: Organizational and Legal Structures; Governance

Health Care Evolution

The Accountable Care Organization Specific Objectives

Recent Developments in Stark and Anti-Kickback Statute Enforcement

Assignment of Medicare Fee-for-Service Beneficiaries

Physician Only ACOs: An Opportunity to Consider * Elias N. Matsakis, Esq.

INTRODUCTION TO POPULATION HEALTH. Kathy Whitmire, Vice President

Accountable Care Organizations: Process and Applications. Presentation to South Carolina Hospital Association CO CFO Forum.

Physician Compensation in an Era of New Reimbursement Models

February 9, 2012 Orlando, Florida

Episode Payment Models Final Rule & Analysis

MACRA & Implications for Telemedicine. June 20, 2016

ACOs, QPP, and VBP: Oh MI! Flex Reverse Site Visit July 17, 2018

The Quality Payment Program: Your Questions Answered

1. The new state-based insurance exchange for small businesses (SHOP) stands for:

Alternative Payment Models and Health IT

EHR/Meaningful Use

Meaningful Use of EHR Technology:

December 3, 2010 BY COURIER AND ELECTRONIC MAIL

3/16/2016. Swapping, Kickbacks, Fair Market Value: Risks for a Post-Acute Provider. AKS designed to prevent improper referrals, which can lead to:

CMS Quality Payment Program: Performance and Reporting Requirements

A Day in the Life of a Compliance Officer

Swapping, Kickbacks, Fair Market Value: Risks for a Post-Acute Provider

Exhibit 1. Medicare Shared Savings Program: Year 1 Performance of Participating Accountable Care Organizations (2013)

08/07/2015. Next Generation ACO Model. What is an ACO? Preliminary Beneficiary Engagement Timeline

Advancing Care Information- The New Meaningful Use September 2017

Medicare Quality Payment Program: Deep Dive FAQs for 2017 Performance Year Hospital-Employed Physicians

Overview of the Changes to the Meaningful Use Program Called for in the Proposed Inpatient Prospective Payment System Rule April 27, 2018

MACRA Frequently Asked Questions

Rural and Independent Primary Care.

ACOs the Medicare Shared Savings Program And Other Healthcare Reform Payment Methods

MEMORANDUM. TO: Infectious Diseases Society of America FROM: King & Spalding

Kate Goodrich, MD MHS. Director, Center for Clinical Standards & Quality. Center for Medicare and Medicaid Services (CMS) May 6, 2016

Diane Meyer, CHC (650) Agenda

Re: Payment Policies under the Physician Fee Schedule Proposed Rule for CY 2014; 78 Fed. Reg. 43,281 (July 19, 2013); CMS-1600; RIN 0938-AR56

Furthering the agency s stated intention to pay for value over volume,

Division C: Increasing Choice, Access, and Quality in Health Care for Americans TITLE XV: Provisions Relating to Medicare Part A

ESSENTIAL STRATEGIES IN MEDI-CAL PAYMENT REFORM. Richard Popper, Director, Medicaid & Duals Strategy August 3, 2017

Transitioning to a Value-Based Accountable Health System Preparing for the New Business Model. The New Accountable Care Business Model

May 25, SUBMITTED ELECTRONICALLY VIA Adam Boehler Deputy Administrator and Director

QUALITY PAYMENT PROGRAM

March Data Jam: Using Data to Prepare for the MACRA Quality Payment Program

Small Rural Hospital Transitions (SRHT) Project. Rural Relevant Measures: Next Steps for the Future

Practice Transformation Networks

3/29/2013. Effective ACO Compliance. Objectives THE HEALTH CARE DILEMMA: ARE ACOS THE ANSWER? HCCA Compliance Institute April 21, 2013

Medicare & Medicaid EHR Incentive Program Specifics of the Program for Hospitals. August 11, 2010

The Evolving Landscape of Healthcare Payment: Incentive Programs and ACO Model Optimization. Quality Forum August 19, 2015

Re: Medicare Program; Medicare Shared Savings Program: Accountable Care Organizations, Proposed rule.

ACCOUNTABLE CARE ORGANIZATION & ALTERNATIVE PAYMENT MODEL SUMMIT

CPC+ Oregon Practice Application Webinar. David Dorr, MD, MS Ron Stock, MD, MA

HEALTH CARE REFORM IN THE U.S.

NY State initiatives for Primary Care Practices: CPC plus - Webinar

Implementing Medicaid Value-Based Purchasing Initiatives with Federally Qualified Health Centers

SUBJECT: WIC Policy Memorandum # Medicaid Primary Payer for Exempt Infant Formulas and Medical Foods

MEDICARE COMPREHENSIVE CARE FOR JOINT REPLACEMENT MODEL (CCJR) Preparing for Risk-Based Outcomes of Bundled Care 8/12/2015.

Agenda. Meaningful Use: What You Really Need to Know. Am I Eligible? Which Program? Meaningful Use Progression 6/14/2013. Overview of Meaningful Use

Medi-Pak Advantage: Reimbursement Methodology

Decoding the QPP Year 2 Quality Measure Benchmarks and Deciles to Maximize Performance

2017 Physician Fee Schedule Impact on Medicare ACOs REGULATORY UPDATES

MIPS Advancing Care Information: Tips, Tools and Support Q&A from Live Webinar March 29, 2017

RE: RIN 0938-AQ22, Final Rule, Section 3022 of the Affordable Care Act, Medicare Shared Savings Program: Accountable Care Organizations

Maximizing Your Potential Under MIPS Oregon MACRA Playbook Conference

HITECH* Update Meaningful Use Regulations Eligible Professionals

Practice Implications for Accountable Care Organizations

Are physicians ready for macra/qpp?

Overview of Quality Payment Program

New Mexico Medicaid Electronic Health Records Incentive Payment Program

2016 Requirements for the EHR Incentive Programs: EligibleProfessionals

MACRA, MIPS, and APMs What to Expect from all these Acronyms?!

RE: CMS-1677-P; Medicare Program; Request for Information on CMS Flexibilities and Efficiencies

Critical Access Hospital Quality

CMS-0044-P; Proposed Rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program Stage 2

Medicare Physician Payment Reform:

Glossary of Acronyms for the Quality Payment Program

Strategic Implications & Conclusion

Community Paramedicine Seminar July, 20th 2015

CPC+ Application Process

Frequently Asked Questions

AHLA. David A. DeSimone Vice President and General Counsel AtlantiCare Egg Harbor Township, NJ

4/9/2016. The changing health care market THE CHANGING HEALTH CARE MARKET. CPAs & ADVISORS

CMS Bundled Payments Initiative

CMS Meaningful Use Incentives NPRM

Data-Driven Strategy for New Payment Models. Objectives. Common Acronyms

Final Meaningful Use Stage 3 Requirements Released August 2018

The MIPS Survival Guide

Statement for the Record. American College of Physicians. Hearing before the House Energy & Commerce Subcommittee on Health

AMGA Webinar: MSSP Final Rule. Scott Hines, MD Chief Quality Officer Crystal Run Healthcare July 16, 2015

Medicare Fee-For Service Provider Utilization & Payment Data Inpatient Public Use File: A Methodological Overview

PHCA Webinar January 30, Latsha Davis & McKenna, P.C. Kimber L. Latsha, Esq.

Hospice Program Integrity Recommendations

MACRA and MIPS. How Medicare Meaningful Use and PQRS are Changing

RE: Request for Information: Centers for Medicare & Medicaid Services, Direct Provider Contracting Models

WELCOME. Kate Gainer, PharmD Executive Vice President and CEO Iowa Pharmacy Association

Welcome to Making Sense of Accountable Care. What s in it for you?

Transcription:

ACO REVIVAL Medicare Shared Savings Program Final Regulation Overview Blue & Co., LLC Healthcare Reform Symposium Thursday, November 3, 2011 11/03/2011 1

Introductions John Redding, MD, MBA Manager Healthcare Consulting Practice jredding@blueandco.com (312) 504-1624 John Redding, MD is a Manager in Blue Consulting Services Healthcare Consulting Practice. John brings over 15 years of healthcare experience to Blue and has served as a trusted advisor to providers and healthcare executives for the last 6 years. In his role at Blue, John works with health systems, hospitals, and physician organizations to develop collaborative physician-hospital working relationships and business ventures. John has extensive experience leading and supporting a broad spectrum of physician-hospital alignment initiatives, from developing and implementing physician employment strategies to providing interim management for a Clinically Integrated Physician Network / Accountable Care Organization. 11/03/2011 2

Relevant Acronyms Short List ACO = Accountable Care Organization FTC = Federal Trade Commission APM = Advanced Payment Model HHS = Department of Health & Human Services CAH = Critical Access Hospital IME = Indirect Medical Education CI = Clinical Integration LVRH = Low Volume Rural Hospital CMS = Center for Medicare and Medicaid Services MSSP = The Medicare Shared Savings Program DOJ = US Department of Justice OIG = The Office of the Inspector General DSH = Disproportionate Shares Hospital PSA = Primary Service Area FQHC = Federally Qualified Health Center RHC = Rural Health Center 11/03/2011 3

Agenda Context Modifications to the Proposed Regulations Coordination with Other Agencies Impact Analysis Conclusions 11/03/2011 4

Context 11/03/2011 5

The Proposed ACO Regulations Were A Non- Starter For Most Hospitals & Health Systems Proposed regulations published in the Federal Registry April 7 th, 2011 Comment period opened though June 5 th, 2011 Received 1320 comments during the 60 day period Serious concern over the direction of the Proposed Rule On its face, it [the Proposed Rule] is overly prescriptive, operationally burdensome, and the incentives are too difficult to achieve to make this voluntary program attractive. American Medical Group Assoc. 11/03/2011 6

Modifications To The Proposed Regulations 11/03/2011 7

Eligibility The MSSP Is Now A More Inclusive Program Provided a means for RHCs and FQHCs to establish ACO independently Allow additional participants to join an ACO that is formed by one or more of the following participants: ACO professionals in group practice arrangements Networks of individual practices of ACO professionals Partnerships or joint venture arrangements between hospitals and ACO professionals Hospitals employing ACO professionals CAHs that bill under Method II RHCs FQHCs Removed requirement that 50% of the ACO s primary care physicians must be meaningful users of the electronic health record by the second year of the program 11/03/2011 8

Start Dates ACOs Are Being Given Time To Ramp Up Three options for participation: 1. April 1, 2012 Term of Agreement is 3 years and 9 months First period 21 months 2. July 1, 2012 Term of agreement is 3 years and 6 months First period 18 months 3. January 1, 2013 and beyond Term of agreement is 3 years First period is 12 months 11/03/2011 9

Beneficiary Assignment ACOs Will Be Accountable For Patients They See Preliminary attribution Retrospective assignment Stepwise process 1. Plurality of primary care services from ACO affiliated PCP 2. Primary care services provided by other ACO affiliated professionals (specialists, NPs, Pas, etc.) Must notify of adding or removing ACO providers or suppliers within 30 days 11/03/2011 10

Expense Benchmarks A Better Reflection Of The Population Served General methodology as proposed Adjustments made for: Newly assigned beneficiaries Changes in health status of continuously assigned beneficiaries IME & DSH payments excluded 11/03/2011 11

Quality & Reporting Standards New Program Is More Fair & Manageable Reduced measure set from 65 t0 33 measures in four domains Must report all measures in each domain Must achieve satisfactory performance on 70% of the measures within each domain EHR adoption included as a quality measure Must complete a patient experience survey based on CHAPs 11/03/2011 12

Finance The MSSP s Value Proposition Has Increased ACOs have the option to request interim payment Removed risk from the one-sided model Capped share at: One-sided model: 50% or 10% of prospective benchmark Two-sided model: 60% or 15% of prospective benchmark Shared savings provided on a first dollar basis Shared losses recouped on a first dollar basis Removed the 25% withhold of shared savings Extended timeframe for repayment of losses from 30 to 90 days 11/03/2011 13

Coordination With Other Agencies 11/03/2011 14

Coordination With Other Agencies Agencies Do Not Want To Impede ACO Adoption Federal Trade Commission & The US Department of Justice Guidance applies to all ACOs No mandatory anti-trust review Voluntary expedited review (90 days) CMS to share application & data Safe harbor for ACOs with less than 30% market share in their PSA or under the rural exception Will vigilantly monitor complaints about ACO formation or conduct and take whatever enforcement action may be appropriate. Internal Revenue Service (for comment) ACOs engaged exclusively in the MSSP would still qualify for tax exempt status under 501(3)(c) Participation in the MSSP through an ACO will further the charitable purposes of the tax exempt organization The tax exempt organization does not have to have control over the ACO In general, will not consider participation inurement or impermissible private benefit Office of the Inspector General (for comment) Do not want to unduly limit impede development of beneficial ACOs Applies to Physician Self-Referral Law, Federal Anti- Kickback Statute, and the Civil Monetary Penalties Law Five proposed waivers 1. ACO Pre-Participation Waiver 2. ACO Participation Waiver 3. Shared Savings Distribution Waiver 4. Compliance with Physician Self-Referral Law 5. Patient Incentive Waiver Center for Medicare & Medicaid Innovation Advanced Payment ACO Model Start up capital for physician-only ACOs and rural ACOs Up to 50 ACOs ($170 M in funding) Must indicate interest in CMS filing Recipients selected based on formula 11/03/2011 15

Impact Analysis 11/03/2011 16

Impact Analysis The CMS Anticipates Changes Will Spur Adoption Participants 50 to 270 ACOs Federal Savings $470M Bonus Payments $1.31B Start Up Costs $29M to $ 157M Operating Costs $63M to $342M 11/03/2011 17

Conclusions 11/03/2011 18

The ACO Will Be A Viable Model For Some And Will Impact Many The CMS & HHS have made significant modifications to their proposed regulations to increase the value proposition of the MSSP to hospitals and health systems Hospitals & health systems that dismissed the ACO model based on the proposed regulations would be wise to reconsider the opportunity provided by the program under the final regulations Although the MSSP will not be universally attractive, it is likely to impact a number of local and regional healthcare markets Hospital leaders should evaluate and begin planning for the potential impact of ACOs in their markets Whether or not participation in the MSSP is right for your organization at this time, business as usual will not be a sustainable long-term strategy 11/03/2011 19

Questions & Answers Manager Healthcare Consulting Practice jredding@blueconsultingservices.com (312) 504-1624 11/03/2011 20