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Perspectives on a selected key
topic
March / April 2022 |
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are your impressions and implications of the CMS ACO REACH model
that will replace their GPDC direct contracting entity model?"
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Chris Smedley
Director, BDC Advisors
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CMS and CMMI have announced the continuation of Direct
Contracting (DC), but the program has been rebranded as ACO
REACH Model. This change is significant and acknowledges the
need to promote health equity and address healthcare
disparities for underserved communities. It also recognizes
the importance of clinician voice and provider-led
organizations participating in these programs that will
undoubtedly undergo increased levels of vetting to ensure
that their goals align with the vision of CMS.
It's hard to find a boardroom that isn’t focused on
addressing health equity and disparities today. As a matter
of fact, I cannot think of one. And, while many
organizations are still predominantly focused on
fee-for-service, all are faced with the challenge of
navigating value-based payment models to some degree. The
ACO REACH Model reflects the convergence of the two, and it
has the potential to shape healthcare delivery for the
future.
The current DC program will remain
unchanged until 2023 when it sunsets, and ACO REACH takes
its place as the next step in CMS ongoing efforts to reduce
Medicare expenditures and enhance quality and accessibility
for beneficiaries. Applications are currently open through
April 22, 2022 for model year 2023. A few highlights of the
new program include:
• Continuation of DC
program’s partial and global capitation options, with
benchmark adjustments designed to reward providers serving a
greater portion of medically underserved Medicare or
dual-eligible beneficiaries.
• ACO REACH adds a Nurse
Practitioner benefit enhancement, requires substantial
demographic data gathering and analysis, and reduces Global
Discount reductions and the amount of Quality Withhold.
• Participating providers or their reps will need to hold at
least 75% of voting board seats up from 25% in the expiring
DC model.
• In addition, Boards must include both a
Consumer Advocate and a separate Medicare Beneficiary
representative.
• CMS has improved ACO REACH Global Risk
Sharing Option financial attractiveness by capping
deductions to deter risk score coding growth from 4% to 3%
for PY024 and from 5% to 3.5% for P2025 and 2026.
• The
Quality Withhold has also been reduced for all entities from
5% to 2% of the benchmark year.
Despite the
additional administrative requirements, CMS’s improvements
are positive, advancing the interests of both providers and
program beneficiaries in ways that further the goals of
value-based care. Participating DC Entities can continue in
the ACO REACH program if they meet the new governance
requirements, as well as being open to qualifying health
systems wishing to enter the value-based market on their
own. Early adopters will have the benefit of learning and
adapting to these new models, with the potential to exit the
program before the model year begins.
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Clive Riddle
President
MCOL
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A significant component of the new ACO REACH Model are the
health equity provisions. Here’s how CMS touted the changes
in their announcement: “The ACO REACH Model promotes health
equity and focuses on bringing the benefits of accountable
care to Medicare beneficiaries in underserved communities.
CMS will use an innovative payment approach to better
support care delivery and coordination for patients in
underserved communities and will require that all model
participants develop and implement a robust health equity
plan to identify underserved communities and implement
initiatives to measurably reduce health disparities within
their beneficiary populations.”
The ACO REACH
Model is introducing five new policies to promote health
equity starting in PY2023:
1. Health Equity
Plan Requirement
2. Health Equity Benchmark Adjustment
3. Health Equity Data Collection Requirement
4. Nurse
Practitioner Services Benefit Enhancement
5. Health
Equity Questions in Application and Scoring for Health
Equity Experience
With respect to the Health
Equity Plan, currently the Accountable Health Communities
(AHC) Model is the only CMMI model to require such a plan.
In the ACO REACH Model, each ACO will use a Health Equity
Plan to identify underserved communities within its
beneficiary population and implement initiatives to measure
and reduce health disparities for such populations over the
course of the model performance period. CMMI will provide
ACOs with a template based on the CMS Disparities Impact
Statement created by the CMS Office of Minority Health to
identify health disparities, define health equity goals,
establish a health equity strategy, and a plan for
implementing the health equity strategy and monitoring and
evaluating progress to advance health equity for underserved
communities.
Regarding the Benchmark
adjustment, CMS will be applying an adjustment to increase
the benchmark for ACOs serving higher proportions of
underserved beneficiaries, which will be identified using a
composite measure that incorporates a combination of the
Area Deprivation Index and Dual Medicaid Status to ensure
the benefits of ACOs are available to all Medicare
beneficiaries.
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