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CMS Rolls Out Significant Additions to ACO Regulations

Murer Consultants wants to inform you about new developments that may benefit you and your health system.

In March 2011, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the Medicare Shared Savings Program, which allows health care providers to join together as Accountable Care Organizations (ACOs) to share in savings generated for the Medicare program. On May 17, 2011, CMS released changes meant to improve upon the Medicare Shared Savings Program, and that offer attractive options for providers. Specifically, CMS announced the following initiatives:

Pioneer ACO Model - This ACO model is advantageous for many providers because it will allow mature organizations to begin operations as an ACO immediately, with the potential to achieve larger gains in shared savings now. It implements a faster path for those organizations that are already coordinating care for patients as well as operating as an ACO.

Pioneer ACOs will be subject to standards similar to the Medicare Shared Savings Program but have a shared savings policy with generally higher savings and risk. Some of the key differences between the Pioneer ACO Model and the Shared Savings Program Model include a requirement of 15,000 Medicare beneficiaries, and a payment arrangement allowing the ACO to take up to 70 percent (as opposed to 50%) of shared savings and shared losses (capped at 15% of the expenditure benchmark). Interested organizations must file a non-binding Letter of Intent with CMS by June 10, 2011.

Advance Payment ACO Initiative - CMS is considering pre-paying ACOs for future savings to incentivize early participation in ACOs. CMS is seeking comment on this initiative, which will provide monthly payments for each aligned Medicare beneficiary. Early comments on the ACO proposed rule indicate that a lack of immediate access to capital may hinder the development of the requisite infrastructure for an ACO. Comments are due by June 17^th, and Murer Consultants will draft comments on behalf of providers, if needed.

Murer Consultants believes these changes offer significant advantages for providers and highly encourages organizations that may be positioned to become a Pioneer ACO to contact our office for more information or assistance in navigating the challenges imposed by ACOs and healthcare reform. We will continue to update our clients on regulatory changes and expect to see further announcements from CMS.

Please feel free to Murer Consultants at (815) 727-3355 if you have any questions, comments or concerns regarding the aforementioned regulation additions.

We will be happy to assist you.

Murer Consultants