CMS announced in April its list of the 27 inaugural accountable care organizations participating in the Medicare Shared Savings Program, adding to the 32 Pioneer ACOs that preceded the MSSP participants. While the March 30 deadline to apply for the second round of the MSSP has passed, accountable care organizations looking to become a part of the program — thereby taking on the challenge of meeting quality metrics while reducing costs and potentially sharing the money saved — should start gearing up to file a notice of intent with CMS for the third round.
Joe Damore, vice president of engagement and delivery at the Premier healthcare alliance, and Jacqueline Gisch, vice president of quality at Milwaukee-based Aurora Health Care, which submitted an application to participate in MSSP and awaits CMS' decision later this spring, spoke at a recent webinar sponsored by Premier Healthcare Alliance called "Joining CMS' MSSP: Why It's Worth It."
Here are eight important ideas from that webinar, and things for any organization to keep in mind when applying for MSSP.
1. The notice of intent to apply for the next round of is due June 15. No exceptions. CMS has been stringent with enacting deadlines for this program. Mr. Damore said even if your organization is merely exploring the option of applying, it should file a notice of intent with CMS. The notice won't marry any healthcare organization to any agreement; it merely leaves the door open should it choose to do so. Without filing a notice of intent by June 15, aspiring ACOs will be unable to move any further in the MSSP application process for at least some time. CMS has yet to announce any information about a fourth round.
2. Before drafting an application, carefully read through all the MSSP guidelines. Be sure to have a clear understanding of MSSP and whether or not your organization qualifies to participate — a good place to start is the CMS FAQ on MSSP. ACOs must be identified by a tax identification number and bill Medicare for services through its Medicare-enrolled TIN, or CMS Certification Number. These numbers are the basis for establishing eligibility, assignment of beneficiaries, computation of the benchmark, and quality assessment.
As part of the application submitted to CMS, an ACO must prove that all participants are on board by submitting copies of contracts, signed agreements or operation policies to CMS. ACOs will be required to submit a list of participants to CMS, which could include a number of healthcare organizations: group practices, acute care hospitals, pharmacies, a solo practices, federally qualified health centers, critical access hospitals and rural health centers may all qualify to participate.
Seventy-five percent of an ACO's governing body needs to include Medicare ACO participants and the ACO must be large enough to cover at least 5,000 fee-for-service beneficiaries.
3. Assigning a project manager in charge of the application will ease the process. This person needs to have some sort of understanding of the structure of your organization and collaborate with all stakeholders in the prospective ACO, including:
5. Be sure your IT team is equipped for massive uploads to the CMS database. Aurora Health Care had a problem when crunch time came and it had to upload PDFs to CMS. The healthcare system "had some file size issues," Ms. Gisch said. Her advice to future applicants: "Check in with your IT folks and make sure there are not glitches." Aurora learned at the last minute it had certain limitations on the file sizes it could upload. In a moment of desperation, Aurora had to Fed Ex a disk to CMS with application data files on it. Fortunately for Aurora, it all worked out. In hindsight, it would have been less stressful to iron out IT issues before the day of submission.
6. Check CMS' website often. CMS has been known to update its submission guidelines without necessarily issuing a news release or blog post. It might be a good idea to assign someone on staff the task of keeping tabs on CMS' MSSP web page. The last thing any healthcare organization wants is to spend hours fixing something tedious such as a formatting issue or, even worse, being disqualified from MSSP because it forgot to include materials CMS recently added to its online checklist.
7. Expect CMS to ask for additional information, but provide as much upfront as possible. Aurora had to re-submit portions of its application that were too vague for CMS' liking. While it may be a good idea to budget time and resources into planning redrafts and submitting more information, or clarifying submitted content, offer as much information as possible upfront. Be clear and specific about everything. For example, Aurora spelled out its guidelines for protecting patient data information in the application because the organization was requesting data files from CMS; ACOs can choose not to request data. Specificity and proof that a robust record protection system was already in place — that Aurora has an internal system for making sure data is kept secure — helped Aurora breeze through that part of the application.
8. Final applications are due August 30 and there are no exceptions. Once your ACO files its notice of intent on or before June 15, it has a 30-day window beginning August 1 to submit all required materials to CMS. When Aug. 30 rolls around, all materials need to be submitted to CMS either electronically or by mail, or else the ACO will not be considered for the MSSP. Organizations should know by fall 2012 whether they have been chosen; CMS has a reconsideration review deadline of Dec. 11 for ACOs not selected, and the anticipated start date for the third round of MSSP participants is January 1, 2013.
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Correction: A previous version of this story stated Aurora had already been chosen for the Medicare Shared Savings Program. While it has submitted all materials, it still awaits a final CMS decision. We apologize for the error.
Joe Damore, vice president of engagement and delivery at the Premier healthcare alliance, and Jacqueline Gisch, vice president of quality at Milwaukee-based Aurora Health Care, which submitted an application to participate in MSSP and awaits CMS' decision later this spring, spoke at a recent webinar sponsored by Premier Healthcare Alliance called "Joining CMS' MSSP: Why It's Worth It."
Here are eight important ideas from that webinar, and things for any organization to keep in mind when applying for MSSP.
1. The notice of intent to apply for the next round of is due June 15. No exceptions. CMS has been stringent with enacting deadlines for this program. Mr. Damore said even if your organization is merely exploring the option of applying, it should file a notice of intent with CMS. The notice won't marry any healthcare organization to any agreement; it merely leaves the door open should it choose to do so. Without filing a notice of intent by June 15, aspiring ACOs will be unable to move any further in the MSSP application process for at least some time. CMS has yet to announce any information about a fourth round.
2. Before drafting an application, carefully read through all the MSSP guidelines. Be sure to have a clear understanding of MSSP and whether or not your organization qualifies to participate — a good place to start is the CMS FAQ on MSSP. ACOs must be identified by a tax identification number and bill Medicare for services through its Medicare-enrolled TIN, or CMS Certification Number. These numbers are the basis for establishing eligibility, assignment of beneficiaries, computation of the benchmark, and quality assessment.
As part of the application submitted to CMS, an ACO must prove that all participants are on board by submitting copies of contracts, signed agreements or operation policies to CMS. ACOs will be required to submit a list of participants to CMS, which could include a number of healthcare organizations: group practices, acute care hospitals, pharmacies, a solo practices, federally qualified health centers, critical access hospitals and rural health centers may all qualify to participate.
Seventy-five percent of an ACO's governing body needs to include Medicare ACO participants and the ACO must be large enough to cover at least 5,000 fee-for-service beneficiaries.
3. Assigning a project manager in charge of the application will ease the process. This person needs to have some sort of understanding of the structure of your organization and collaborate with all stakeholders in the prospective ACO, including:
- Administrative leadership
- Clinical leadership
- Clinical staff
- Human resources
5. Be sure your IT team is equipped for massive uploads to the CMS database. Aurora Health Care had a problem when crunch time came and it had to upload PDFs to CMS. The healthcare system "had some file size issues," Ms. Gisch said. Her advice to future applicants: "Check in with your IT folks and make sure there are not glitches." Aurora learned at the last minute it had certain limitations on the file sizes it could upload. In a moment of desperation, Aurora had to Fed Ex a disk to CMS with application data files on it. Fortunately for Aurora, it all worked out. In hindsight, it would have been less stressful to iron out IT issues before the day of submission.
6. Check CMS' website often. CMS has been known to update its submission guidelines without necessarily issuing a news release or blog post. It might be a good idea to assign someone on staff the task of keeping tabs on CMS' MSSP web page. The last thing any healthcare organization wants is to spend hours fixing something tedious such as a formatting issue or, even worse, being disqualified from MSSP because it forgot to include materials CMS recently added to its online checklist.
7. Expect CMS to ask for additional information, but provide as much upfront as possible. Aurora had to re-submit portions of its application that were too vague for CMS' liking. While it may be a good idea to budget time and resources into planning redrafts and submitting more information, or clarifying submitted content, offer as much information as possible upfront. Be clear and specific about everything. For example, Aurora spelled out its guidelines for protecting patient data information in the application because the organization was requesting data files from CMS; ACOs can choose not to request data. Specificity and proof that a robust record protection system was already in place — that Aurora has an internal system for making sure data is kept secure — helped Aurora breeze through that part of the application.
8. Final applications are due August 30 and there are no exceptions. Once your ACO files its notice of intent on or before June 15, it has a 30-day window beginning August 1 to submit all required materials to CMS. When Aug. 30 rolls around, all materials need to be submitted to CMS either electronically or by mail, or else the ACO will not be considered for the MSSP. Organizations should know by fall 2012 whether they have been chosen; CMS has a reconsideration review deadline of Dec. 11 for ACOs not selected, and the anticipated start date for the third round of MSSP participants is January 1, 2013.
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Correction: A previous version of this story stated Aurora had already been chosen for the Medicare Shared Savings Program. While it has submitted all materials, it still awaits a final CMS decision. We apologize for the error.