On February 24, 2022, the Facilities for Medicare & Medicaid Companies (“CMS”) introduced a redesign of the International Skilled Direct Contracting (“GPDC”) Mannequin for Direct Contracting Entities (“DCEs”). The revamped mannequin will probably be often called the Accountable Care Group (“ACO”) Realizing Fairness, Entry, and Neighborhood Well being (REACH) Mannequin. The ACO REACH Mannequin contains vital modifications to the GPDC Mannequin in three areas: (1) advancing well being fairness; (2) selling provider-led organizations; and (3) defending beneficiaries with better participant vetting and monitoring. CMS has launched a Request for Purposes (“RFA”) for provider-led organizations excited about starting participation for the ACO Attain Mannequin, which can take impact on January 1, 2023 and can span 4 Efficiency Years, ending on December 31, 2026. DCE’s presently taking part within the GPDC Mannequin will probably be permitted to proceed taking part within the ACO REACH Mannequin supplied that they maintain a strong compliance report within the GPDC Mannequin and agree to satisfy the necessities of the ACO REACH Mannequin by January 1, 2023.
A. Utility course of
To take part within the ACO REACH Mannequin, all new organizations excited about starting participation are required to submit an software. The applying portal opened on March 7, 2022 and all functions are due by 11:59 PM E.T. on April 22, 2022. Accepted candidates can have the choice of taking part in an Implementation Interval which can run from August 1, 2022 via December 31, 2022 to arrange for a January 1, 2023 launch.
Organizations that presently take part within the GPDC Mannequin and want to proceed participation within the ACO REACH Mannequin, might want to execute an Amended and Restated Participation with CMS by January 1, 2023 in an effort to transition into the ACO REACH Mannequin.
B. Utility standards concerns
The earlier software scoring standards for the GPDC targeted on the next: (1) organizational construction; (2) management and administration; (3) monetary plan and risk-sharing expertise; (4) affected person centeredness and beneficiary engagement; and (5) medical care. Along with the 5 areas listed above, the brand new ACO REACH software considers the next:
- Sturdy monitor report of direct affected person care;
- Document of serving underserved communities with constructive high quality outcomes; and
- Program integrity dangers posted by ACO possession.
C. ACO REACH Mannequin group varieties
An vital facet of the ACO REACH Mannequin is offering new alternatives for organizations which have historically participated in value-based care preparations within the Medicare Price-For-Service (FFS) inhabitants. Along with conventional suppliers, the ACO REACH Mannequin additionally offers alternatives for provider-led organizations with out a lot expertise in FFS, however which have a powerful report of taking danger and enhancing high quality of look after seniors and susceptible populations.
Beneath the ACO REACH Mannequin, there are three sorts of ACOs with completely different traits. The three varieties are:
- Normal ACOs – This class is meant for ACOs with substantial expertise serving Medicare FFS beneficiaries. These ACOs could have beforehand participated in one other shared financial savings mannequin or could also be newly fashioned organizations comprised of present Medicare suppliers and suppliers.
- New Entrant ACOs –This class is meant for ACOs comprised of organizations that haven’t historically supplied providers to a Medicare FFS inhabitants.
- Excessive Wants inhabitants ACOs – This class is meant for ACOs that serve Medicare populations with complicated wants. Excessive Wants Inhabitants ACOs should make the most of a mannequin of care designed to serve complicated want sufferers.
D. Danger sharing choices
Much like the GPDC Mannequin, the ACO REACH Mannequin will supply two voluntary danger choices:
- Skilled possibility: This decrease danger possibility features a 50 p.c Shared/Financial savings/Shared Losses and Main Care Capitation Cost; and
- International possibility: This full danger possibility features a 100% Shared Financial savings/Shared Losses and both Main Care Capitation Cost or Whole Care Capitation Cost.
The ACO REACH Mannequin offers alternatives for each present GPDC contributors in addition to new contributors to proceed on the journey to value-based care.
Extra info on the ACO REACH Mannequin will be discovered right here and an in depth comparability of the GPDC and ACO REACH Mannequin will be discovered right here. In case you have any questions associated to making use of for or transitioning a DCE to the ACO REACH Mannequin, please don’t hesitate to contact Thompson Coburn’s Well being Legislation Apply Group.
Tonya Oliver Rose and Elisabeth Volk are members of Thompson Coburn’s Well being Care group.
