As of January 2016, there were 433 Medicare Shared Savings Program (MMSP) Accountable Care Organizations (ACOs) with almost 7.7 million assigned beneficiaries and more than 14,000 participants (a participant may be a group or an individual). Most of these ACOs are one-sided model ACOs that may generate shared savings and do not involve shared losses (Track 1 ACOs).
Importantly, Track 1 ACOs are not considered advanced alternative payment models (APMs) for purposes of MACRA. As a result, a clinician participating in a Track 1 ACO is subject to the merit-based incentive payment system (MIPS) just like a clinician that is not in an ACO (a participant in an advanced APM is not subject to MIPS).
However, participating in a Track 1 ACO may confer MIPS scoring benefits on a clinician if the clinician reports MIPS data through the Track 1 ACO entity. The scoring benefits are that:
- The MIPS cost/resource use scoring does not apply to Track 1 ACO participants – the cost/resource use weighting is redistributed to clinical practice improvement and advancing care information categories.
- Track 1 ACO participants automatically receive a baseline score for the clinical practice improvement category based on CMS’ determination clinical practice activities of Track 1 ACOs.
A clinician that reports through a Track 1 ACO entity will get at least the MIPS score calculated for the Track 1 ACO overall – and a Track 1 ACO participant may report additional data in certain circumstances to get a higher score.
In addition to the MIPS scoring benefit, participation in a Track 1 ACO may have benefits regarding a clinician’s reporting of MIPS data. Specifically, with respect to the four performance categories:
- Quality – a Track 1 ACO participant is not responsible for reporting quality data but can report data if the ACO fails to report.
- Cost/Resource Use – No data reporting because this category does not apply to Track 1 ACO participants.
- Clinical Practice Improvement – If the ACO gets the highest score, then all participants get the highest score, but if the ACO does not get the highest score, ACO participants may submit data to add to the baseline score.
- Advancing Care Information – Track 1 ACO participants report advancing care information (just like non-ACO clinicians), but the data is aggregated for the ACO. If the ACO fails to meet quality reporting measures, advancing care information scores are not aggregated.
These benefits under MACRA create additional incentives for clinicians considering whether to join a Track 1 ACO. However, it is important for clinicians considering joining any ACO to determine whether and to what extent the ACO will benefit the clinician – in the context of both potential shared savings (and, if applicable, losses) and MIPS scoring under MACRA. The types of information that will be important are historical data about ACO performance (if available), which will indicate how quality performance scoring may be impacted, and clinical practice improvement and advancing care information efforts of the ACO (e.g. if the ACO actively working with participants to enhance scores or if it is entirely passive about these issues).