ACOs should plan for shorter path to greater risk in CMS' overhauled MSSP

Accountable care organizations seeking to participate in the overhauled Medicare Shared Savings Program should expect a shorter period of time to begin to reap savings through their efforts to better manage their patient populations before the Centers for Medicare & Medicaid Services expects them to shoulder more risk.

So they'd better plan accordingly, according to a new report from healthcare consulting firm Leavitt Partners.

The overhauled MSSP program divides ACOs into two tracks based on Medicare revenue that determine how much time they have before they must take on additional financial risk.

In an analysis of Medicare data for 560 MSSP ACOs to estimate where they would fall in CMS’ new two-prong model, two out of three ACOs had the shorter window before they would be expected to take on greater risk.

RELATED: CMS finalizes ACO overhaul, shortening pathway for financial risk 

However, CMS will not issue high- or low-revenue designations until after providers have issued an intent to apply to participate in the model.  

David Muhlestein, Ph.D., chief research officer at Leavitt and one of the report’s authors, told FierceHealthcare that providers considering participating in the revamped MSSP should start planning as if they’re already designated a high-revenue ACO. 

“A big part of it is just recognizing that you’re more likely than not to be required to move toward risk after a short period of time,” he said. “And those that won’t have to are certainly in the minority.” 

Applicants that fall into the low-revenue category would have three years to move into a two-sided model, while high-revenue applicants will have two years. Existing MSSP organizations will have one year to take on additional risk.  

Another wrinkle to consider is that Leavitt’s analysis found factors such as size were not useful indicators of whether an ACO would be considered high- or low-revenue. That uncertainty, Muhlestein said, is another reason interested applicants should go into the process anticipating a shorter path to greater risk. 

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“People have to make important decisions before they have the information,” Muhlestein said. 

An additional planning challenge is it’s unclear when CMS will let providers know which category they fall into, he said. If those designations are released close to the formal application deadline—and providers get results they don’t expect—that can make adapting to the model that much harder, Muhlestein said. 

CMS will accept intent to apply notices until Jan. 18. The formal application period is expected to close mid-to-late February.