On the heels of the release of its final rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA), the Centers for Medicare and Medicaid Services (CMS) released a list of additional opportunities for joining Advanced Alternative Payment Models (APMs) in 2017 and 2018. APMs are intended to improve care and offer participating providers the opportunity to earn an incentive payment under the Quality Payment Program created through MACRA. The release of the list provides more certainty to clinicians weighing their options for 2017 and beyond.
By way of brief background, the Quality Payment Program rewards clinicians with sufficient participation in Advanced APMs. By giving more clinicians the opportunity to participate in these models that align incentives for the provision of high-quality, patient-centered care, CMS aims to extend the benefits of high-quality, coordinated care to more Medicare beneficiaries. The CMS Innovation Center (CMMI) tests these innovative care models across the country in an effort to develop sustainable models for the future of healthcare reimbursement.
In its announcement, CMS indicated that it expects to re-open applications for new practices and payers in the Comprehensive Primary Care Plus (CPC+) model and new participants in the Next Generation ACO model for the 2018 performance year. Further, CMS announced that CMMI’s Oncology Care Model with two-sided risk would be available in 2017, thus qualifying the model as an Advanced APM commencing in 2017.
For 2017, under the Quality Payment Program, clinicians may earn a 5 percent incentive payment through adequate participation in the following Advanced APMs:
- Comprehensive ESRD Care Model (Large Dialysis Organization arrangement)
- Comprehensive ESRD Care Model (arrangements for organizations that are not Large Dialysis Organizations)
- Comprehensive Primary Care+
- Medicare Shared Savings Program ACOs – Track 2
- Medicare Shared Savings Program ACOs – Track 3
- Next Generation ACO Model
- Oncology Care Model (two-sided risk arrangement)
For 2018, CMS anticipates that the following models may qualify as Advanced APMs:
- ACO Track 1+
- New voluntary bundled payment model
- Comprehensive Care for Joint Replacement Payment Model (Certified Electronic Health Record Technology (CEHRT) track)
- Advancing Care Coordination through Episode Payment Models Track 1 (CEHRT track)
A few days later, CMS announced the pilot of an Advanced APM designed to incentivize health care value and quality, with a focus on health outcomes, for the majority of Vermont health care providers, as well as Medicare, Medicaid, and commercial health care payers, commencing on January 1, 2017 and ending on December 31, 2022. CMS is expected to provide initial funding of $9.5 million in 2017 for this new payment model, known as the Vermont All-Payer ACO Model, whose aim is to deliver significant improvements in the health of Vermont’s population. In tandem, CMS approved a five-year extension of Vermont’s section 1115(a) Medicaid demonstration, which enables Medicaid to be a full partner in the Vermont All-Payer ACO Model.
Vermont hopes to encourage 70 percent of all residents, including 90 percent of Vermont Medicare beneficiaries, to participate in an ACO. Vermont’s ACO Model will help CMS attain its goal of having 50 percent of all Medicare fee-for-service payments made via alternative payment models by 2018. The Vermont Medicare ACO Initiative is based on CMS’ Next Generation ACO Model and will support ACO design alignment with other Vermont payers’ ACO programs; however, participants in the Vermont Medicare ACO Initiative may not participate in the Medicare Shared Savings Program simultaneously.
These new developments highlight CMS’ commitment to transforming reimbursement models over the next several years. As more cost is borne by employees and Exchange participants in high deductible health plans, innovative models to transform reimbursement models across payors are critical to keeping up with the new wave of healthcare consumers.