WASHINGTON, D.C. (Jan, 2020) – The NGACO Coalition’s Feedback on Direct Contracting Model (excerpt)
CMMI Should Reduce the Financial Exposure in the Direct Contracting (DC) Model
Issue: The current financial model includes a 2-5% discount for global model participants; a 2% retention withhold for early termination; a 5% quality withhold; and a leakage withhold. CMMI limits the maximum upward and downward adjustment that can result from incorporating regional expenditures into the benchmark, with an upward limit of 5% and a downward limit of 2%. CMMI has not yet released the risk adjustment methodology for DC. The total impact of these withholds and discounts represents significant risk exposure for participants.
NGACO Coalition Recommendations:
CMMI should reduce or waive some of the model’s withholds and discounts:
CMMI should waive the 2% retention withhold for entities with experience with two-sided risk as they have made significant investments in the infrastructure to manage risk and have demonstrated their commitment to do so.
CMMI should reduce the discount percentage in the global model.
CMMI should increase the cap on the regional component of the benchmark from 5% to 10% to align with Next Gen. The floor should remain at 2%.
CMMI should ensure that the DC risk adjustment methodology aligns to the risk adjustment methodology for Medicare Advantage (MA) (i.e., uncapped).
In the global model total care capitation track, DCEs should be able to negotiate their capitation with CMS, including the option for a seasonality adjustment to reflect on-the-ground factors specific to the DCE’s patient population. DCEs should have the option for a higher upfront payment and reconciliation, similar to the approach offered for primary care capitation.
CMMI should allow Standard DCEs to nest High Needs DCEs. Removing the most complex subset of the population and those providers creates substantial financial risk and results in an unfair playing field for Standard DCEs as compared to High Needs DCEs.
The full feedback document, including other issues and recommendations, is available here.
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CMS has released three new case studies describing innovative programs from Medicare Accountable Care Organizations (ACOs). The case studies feature ACO initiatives related to:
promoting staff development through leadership academies,
conducting home visits, and
The case studies highlight ACOs participating in the Next Generation ACO Model and the Medicare Shared Savings Program. Each case study includes detailed results and describes lessons learned by the ACO during implementation. By sharing the stories, CMS hopes to help current and future Medicare ACOs, and other providers and entities, find new ways to make care better, people healthier, and spending smarter.
For more information on these case studies, and to view past case studies and the ACO Toolkit on Care Coordination, please visit the ACO General Information web page.
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WASHINGTON, D.C. (May 30, 2019) – The Next Generation (Next Gen) Accountable Care Organization Coalition represents 21 of the existing Next Gen ACOs. We appreciate the opportunity to weigh in as you continue to design and implement the future portfolio of performance-based risk models.
The Next Generation ACO model has demonstrated that organizations can be successful in taking two-sided financial risk. The evaluation of the first performance year of Next Gen resulted in an estimated $63 million in net savings or a 1.1 percent decline in Medicare spending while maintaining quality for patients.
Next Gens have successfully implemented care management programs that are improving care for seniors in traditional Medicare. For example, Next Gens have engaged beneficiaries in transitions of care programs, disease management, social work and health enhancement programs, as well as strengthening relationships with primary care providers. As a result of these care redesign initiatives, Next Gens have achieved reduced readmissions rates, reduced non-emergent use of the emergency department; and improved quality for beneficiaries.
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WASHINGTON, D.C. (May 30, 2019) – The undersigned organizations write to encourage the Department of Health and Human Services to expand the duration and scope of the NGACO model to be a permanent, voluntary offering in the performance-based risk model portfolio beginning with the 2021 performance year. Participants in the NGACO model have demonstrated success in terms of controlling costs for Medicare and improving care for seniors. Extending the availability of this model will allow additional providers to pursue the transition to improved care outcomes and greater levels of financial accountability.
We believe there is sufficient evidence of the model successfully meeting the criteria under Section 1115A authority to expand its duration and scope of participation. However, we call on the agency to begin the work of incorporating the most successful features of the NGACO program into Pathways to Success immediately through regulation (as the agency did with the Pioneer ACO program).1 Making this option available for future participation will support a smooth transition into performance-based risk arrangements for more providers while also building on the lessons learned from successful Innovation Center pilots.
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WASHINGTON, D.C. (Apr. 10, 2019) – CMS has released a public ACO Care Coordination Toolkit showing the work of ACOs and End-Stage Renal Disease Care (ESRD) Seamless Care Organizations (ESCOs) participating in the Shared Savings Program, Next Generation ACO Model, and the Comprehensive ESRD Care Model. The toolkit highlights innovative care coordination strategies that ACOs and ESCOs use to collaborate with beneficiaries, clinicians, and post-acute care partners to ensure high-quality, effective care is provided at the right time and in the right setting. The toolkit aims to educate the public about strategies used by ACOs and ESCOs to provide value-based care while also providing actionable ideas to current and prospective ACOs to help them improve or begin operations.
CMS has also released seven case studies to describe innovative initiatives from ACOs and ESRD ESCOs on a variety of topics including engaging beneficiaries, coordinating care in rural settings, and promoting health literacy. Each case study includes detailed results and lessons learned. By sharing their stories, we hope to help current and future Medicare ACOs, and other providers and entities, find new ways to make care better, people healthier, and spending smarter.
The case studies are available here, under Case Studies.
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WASHINGTON, D.C. (Mar. 26, 2019) – The undersigned organizations write to encourage the CMS Center for Medicare & Medicaid Innovation (Innovation Center) to continue to improve transparency and stability as you develop a successful portfolio of payment models. While we appreciate steps the agency has taken, such as hosting stakeholder roundtable discussions to gather input, we ask that the Innovation Center move to a more methodical and public process for releasing and updating payment models.
Like you, our organizations and the members they represent are committed to the move to alternative payment models (APMs), including those with an emphasis on performance-based risk. We agree that many provider groups of various sizes and composition across the country are prepared to make the leap to greater levels of financial and clinical accountability to improve the health of America’s seniors. Provider organizations that have taken the first step toward two-sided risk models have successfully reduced costs and improved care for patients. We are excited to continue to work with the Innovation Center to pursue new models, many of which will feature increasing levels of financial risk and reward. We are confident that this is the right direction to create a sustainable healthcare delivery system for the future.
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WASHINGTON, D.C. (Dec. 21, 2018) – The Centers for Medicare and Medicaid Services today reported more than $164 million in Medicare savings – with strong performance on quality metrics – for 44 Next Generation Accountable Care Organizations in 2017. This builds on savings of $62 million across 18 Next Generation ACOs in 2016.
“We applaud CMS’s continued support for the move to two-sided models in traditional Medicare,” said Next Gen Coalition Executive Director Mara McDermott. “The strong performance of Next Gen ACOs, which accept the highest levels of performance-based risk, is proof positive that this program works and should be strengthened and continued to improve care delivery for patients.”
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On October 16, 2018, The Next Gen Coalition submitted comments on proposed changes to the Medicare Shared Savings Program. In our letter, we ask that CMS to make the Next Gen program a permanent offering in its Medicare risk portfolio. We also call on the agency to continue to improve transparency and stability while incentivizing the move to performance-based risk.
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WASHINGTON, D.C. (Sept. 20, 2018) – Twenty-nine Next Generation Accountable Care Organizations (ACOs) have formed a new coalition to advocate for the preservation and expansion of the Next Generation ACO program — a program which has benefited individuals, communities and federal payers since its establishment by the Center for Medicare and Medicaid Innovation in 2016.
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On September 5, 2018, 26 Next Gen ACOs sent a letter to CMS Administrator Seema Verma and Deputy Administrator for Innovation and Quality, Adam Boehler. The letter asks that CMS eliminate the three percent ceiling on changes to risk scores, while maintaining the three percent floor; commit to a more predictable and stable payment methodology; and preserve and strengthen the Next Gen program.
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