Completing the Medicare Shared Savings Program application can be an arduous, time-consuming task. CMS offers a toolkit to guide application completion and hosts conference calls for applicants to help ease the process, but for applicants looking for further guidance, three MSSP ACO leaders from two organizations — Jonathan Nasser, MD, and Scott Hines, MD, co-chief clinical transformation officers at Crystal Run Healthcare in Middletown, N.Y.; and Don Franke, vice president of physician integration at Arlington Heights, Ill.-based Alexian Brothers Health System — share some anecdotal tips to help MSSP ACO hopefuls complete the application process, based on their successful experiences applying in years prior.
Applications for MSSP participation starting Jan. 1, 2014, will be accepted July 1 through July 31.
1. Discuss what's already been achieved. Chances are, if an organization is preparing to complete the MSSP application, it has already taken strides to provide patient-centered, high-quality, low-cost care. The MSSP application asks for narrative answers on what the organization is doing in terms of evidence-based medicine and providing patient-centered care. Crystal Run Healthcare found taking a group approach to answering these questions worked best. "We got all leaders in a room and realized that we were already doing a lot of the things they asked on the application," says Dr. Nasser. "Get the leaders together and talk about the mission and ongoing activities of the organization."
Additionally, hospitals, health systems or physician groups that have achieved patient-centered medical home recognition from the National Committee for Quality Assurance have a leg-up on other, non-PCMH recognized organizations, according to Drs. Nasser and Hines. "If groups are already a PCMH, a lot of competencies that CMS is looking for are already displayed by achieving PCMH recognition," Dr. Nasser points out, and he encourages using that experience to ease answering the narrative application questions.
2. Define the governance. Another big chunk of the application covers the ACO's structure and governance, so it is important to define what the governance structure and the leadership of the ACO is going to be. "There is some background thinking to be done in terms of how to set up the ACO in a way that will successfully meet the mission of accountable care," says Dr. Nasser.
"Lining up the governance and the back-office…capabilities was my primary objective during the application phase," agrees Mr. Franke.
It is also important to decide how the ACO will incorporate a Medicare fee-for-service beneficiary on the governing board, which is a requirement for participation. For example, Crystal Run developed a patient advisory panel with seven patient members to incorporate the beneficiaries.
3. Decide if the ACO will receive beneficiary-identifiable claims. MSSP applicants have the choice of requesting beneficiary-identifiable claims data from CMS for Medicare beneficiaries who would be attributed to the ACO. "I would think that most ACOs would want that data, because then you can really decide which patients have the highest opportunity for improved quality and reduced costs," says Dr. Hines. However, requesting beneficiary-identifiable claims information adds length to the MSSP application, because the ACO will have to detail how it plans to use the information and keep it safe.
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