The Centers for Medicare & Medicaid Services (CMS) is preparing to open its doors for another round of Accountable Care Organizations (ACOs) to participate in the Medicare Shared Savings Program (MSSP). This year, CMS is requiring prospective ACOs to declare their intent to apply and to submit applications earlier than last year’s cycle, presumably to give prospective ACOs and CMS more lead time before the start of the three-year participation agreement periods.
Concurrently with this announcement, CMS has also updated its Frequently Asked Questions to address lingering questions about the requirement that individual and group providers offering a majority of primary care services to assigned Medicare beneficiaries and billing for those services using a single Tax Identification Number only join one ACO – a concept known as “exclusivity.” CMS maintains that exclusivity is necessary to ensure that it properly attributes the care, and improvements thereto, that beneficiaries receive from ACO Participants, and that the ACO receives its duly earned proportion of shared savings.
The MSSP has been through three application cycles since January 2012. Over 200 MSSP ACOs are currently participating in the MSSP and providing services for as many as four million Medicare beneficiaries. See our prior posts about the MSSP and related CMS initiatives here.
The deadlines for the 2014 cycle of prospective ACOs are:
- Notices of Intent accepted: May 1, 2013 to May 31, 2013
- CMS User ID forms accepted: May 3, 2013 to June 6, 2013
- MSSP Applications accepted: July 1, 2013 to July 31, 2013
- Application Approval or Denial decisions: Fall 2013
- Reconsideration review deadline: Fall 2013
Prospective ACOs that have been looking forward to this upcoming cycle should confirm that they have the infrastructure and capacity to participate in the MSSP. In addition, applicants should make final revisions to the participation and business associate agreements that they will require participating providers to sign and should develop and adopt the ACO policies with which the ACO Suppliers and Providers must comply.