On February 24, 2022, the Facilities for Medicare & Medicaid Companies (“CMS”) introduced a redesign of the World 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 consists of 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 fascinated with 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 at the moment collaborating within the GPDC Mannequin will probably be permitted to proceed collaborating within the ACO REACH Mannequin offered that they maintain a strong compliance document 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 fascinated with starting participation are required to submit an software. The appliance portal opened on March 7, 2022 and all functions are due by 11:59 PM E.T. on April 22, 2022. Accepted candidates could have the choice of collaborating in an Implementation Interval which can run from August 1, 2022 by way of December 31, 2022 to arrange for a January 1, 2023 launch.
Organizations that at the moment 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 so as to transition into the ACO REACH Mannequin.
B. Utility standards issues
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 observe document of direct affected person care;
- Report 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 side of the ACO REACH Mannequin is offering new alternatives for organizations which have historically participated in value-based care preparations within the Medicare Payment-For-Service (FFS) inhabitants. Along with conventional suppliers, the ACO REACH Mannequin additionally supplies alternatives for provider-led organizations with out a lot expertise in FFS, however which have a powerful document of taking threat and bettering high quality of look after seniors and susceptible populations.
Beneath the ACO REACH Mannequin, there are three kinds of ACOs with totally different traits. The three varieties are:
- Normal ACOs – This class is meant for ACOs with substantial expertise serving Medicare FFS beneficiaries. These ACOs might have beforehand participated in one other shared financial savings mannequin or could also be newly shaped organizations comprised of present Medicare suppliers and suppliers.
- New Entrant ACOs –This class is meant for ACOs comprised of organizations that haven’t historically offered providers to a Medicare FFS inhabitants.
- Excessive Wants inhabitants ACOs – This class is meant for ACOs that serve Medicare populations with advanced wants. Excessive Wants Inhabitants ACOs should make the most of a mannequin of care designed to serve advanced want sufferers.
D. Threat sharing choices
Just like the GPDC Mannequin, the ACO REACH Mannequin will supply two voluntary threat choices:
- Skilled possibility: This decrease threat possibility features a 50 % Shared/Financial savings/Shared Losses and Major Care Capitation Fee; and
- World possibility: This full threat possibility features a 100% Shared Financial savings/Shared Losses and both Major Care Capitation Fee or Whole Care Capitation Fee.
The ACO REACH Mannequin supplies alternatives for each present GPDC individuals in addition to new individuals to proceed on the journey to value-based care.
Extra data 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. When you’ve got 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 Regulation Apply Group.