On February 24, 2022, the Facilities for Medicare & Medicaid Companies (“CMS”) introduced a redesign of the International Skilled Direct Contracting (“GPDC”) Mannequin for Direct Contracting Entities (“DCEs”). The revamped mannequin can be referred to as the Accountable Care Group (“ACO”) Realizing Fairness, Entry, and Group Well being (REACH) Mannequin. The ACO REACH Mannequin contains vital adjustments 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 excited by starting participation for the ACO Attain Mannequin, which is able to take impact on January 1, 2023 and can span 4 Efficiency Years, ending on December 31, 2026. DCE’s presently taking part within the GPDC Mannequin can be permitted to proceed taking part within the ACO REACH Mannequin supplied that they maintain a sturdy 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 excited by starting participation are required to submit an software. The appliance portal opened on March 7, 2022 and all purposes are due by 11:59 PM E.T. on April 22, 2022. Accepted candidates may have the choice of taking part in an Implementation Interval which is able to run from August 1, 2022 via December 31, 2022 to arrange for a January 1, 2023 launch.
Organizations that presently 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 with a view 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) scientific care. Along with the 5 areas listed above, the brand new ACO REACH software considers the next:
- Robust monitor document of direct affected person care;
- File of serving underserved communities with constructive high quality outcomes; and
- Program integrity dangers posted by ACO possession.
C. ACO REACH Mannequin group sorts
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 Charge-For-Service (FFS) inhabitants. Along with conventional suppliers, the ACO REACH Mannequin additionally gives alternatives for provider-led organizations with out a lot expertise in FFS, however which have a powerful document of taking threat and enhancing high quality of look after seniors and susceptible populations.
Below the ACO REACH Mannequin, there are three sorts of ACOs with completely different traits. The three sorts are:
- Customary 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 supplied companies to a Medicare FFS inhabitants.
- Excessive Wants inhabitants ACOs – This class is meant for ACOs that serve Medicare populations with complicated wants. Excessive Wants Inhabitants ACOs should make the most of a mannequin of care designed to serve complicated want sufferers.
D. Danger sharing choices
Just like the GPDC Mannequin, the ACO REACH Mannequin will provide two voluntary threat choices:
- Skilled choice: This decrease threat choice features a 50 % Shared/Financial savings/Shared Losses and Major Care Capitation Cost; and
- International choice: This full threat choice features a one hundred pc Shared Financial savings/Shared Losses and both Major Care Capitation Cost or Whole Care Capitation Cost.
The ACO REACH Mannequin gives alternatives for each present GPDC contributors in addition to new contributors to proceed on the journey to value-based care.
Extra data on the ACO REACH Mannequin may be discovered right here and an in depth comparability of the GPDC and ACO REACH Mannequin may be discovered right here. In case you have 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 Legislation Apply Group.
Tonya Oliver Rose and Elisabeth Volk are members of Thompson Coburn’s Well being Care group.
