NAACOS Leaders Warn That ACOs May Back Out of APM Participation Over Thresholds Issue

Leaders at the Washington, D.C.-based NAACOS (National Association of Accountable Care Organizations) on Sep. 17 warned policymakers that concerns over performance thresholds in advanced payment models (APMs) under the Medicare program, could cause the leaders of some ACOs to leave the risk-based models in the Medicare Shared Savings Program (MSSP), as well as the Next Generation ACO Program.

As stated in a press release posted to NAACOS’s website on Thursday, NAACOS leaders stated that, “In news that threatens Medicare’s move to value-based payment models, more than 90 percent of respondents to a recent survey from the National Association of Accountable Care Organizations said they are concerned they won’t meet thresholds to secure important incentive payments for participating in risk-based alternative payment models, which jump to unrealistic levels in 2021. That concern is validated by the survey’s data, which shows that 96 percent of the 216 ACO respondents would not meet the 2021 thresholds based on their performance in 2020.”

The press release went on to say that, “To help maintain Medicare’s momentum moving to value-based payment, NAACOS is calling on Congress to take swift action to address these thresholds and help stabilize incentives for participating in Advanced APMs, which are designed to make doctors and hospitals financially accountable for lowering patients’ medical spending and improving quality. That 5 percent bonus was part of 2015’s overwhelmingly bipartisan Medicare Access and CHIP Reauthorization Act (MACRA) as an incentive to move toward a system that rewards providers for reducing Medicare spending, yet maintaining high-quality care.”

“These bonuses are critical to Medicare’s value movement,” said Clif Gaus, Sc.D., NAACOS president and CEO, said in Thursday’s press release. “The current thresholds are a challenge for many ACOs. To increase them again in 2021 would put the incentive out of reach for nearly everybody. Congress intended to shift Medicare payment to a value-based approach, and we are seeing the benefits of that transformation through improved patient care and reduced costs. We need Congress to correct these thresholds to prevent the value movement from stalling.”

NAACOS noted that “A 2015 law passed by Congress sought to put Medicare on a financially sustainable path by incentivizing participation in alternative payment models (APMs), which are designed to make doctors and hospitals financially accountable for lowering patients' medical spending and improving quality. That law, MACRA, provides bonuses for participating in risk-bearing Advanced APMs, which include accountable care organizations (ACOs). To earn the bonus, clinicians must meet Qualifying APM Participant (QP) thresholds, which are based on the proportion of payments made under, or patients in, the APM. While the bonuses have been a meaningful incentive, the law increases these thresholds to an unreasonable level starting in 2021, and many doctors, hospitals and ACOs that would qualify under this year’s standard will be ineligible. It’s important to note that ACOs currently comprise the vast majority of those earning Advance APM bonuses.”

The NAACOS survey whose results were released on Thursday, sought the opinions of “all ACOs participating in Advanced APMs, which includes the Medicare Shared Savings Program’s (MSSP’s) Track 1+, Track 2, Basic Level E, Enhanced Track, and the Next Generation ACO Model. The online survey was sent to NAACOS members and non-members, with a request for feedback on the Advanced APM bonus and QP thresholds. There were 216 responses from 116 ACOs across the country.”

As NAACOS noted, “The survey results send a clear and strong message that the Advanced APM bonus has meaningfully supported ACOs moving to risk-based models and has funded patient-focused initiatives such as care coordination efforts. However, in response to rising QP thresholds, ACOs are very concerned they will no longer receive the bonus, which could threaten Medicare’s move to value-based payment. While many ACOs cited attempts to increase their QP scores through efforts such as increased patient outreach, more than 90 percent of ACO respondents reported they are concerned they will not meet the QP thresholds in 2021. There is good reason for their concern, according to the QP scores reported by respondents for the first quarter of 2020, 96 percent would fall short of the 2021 QP payment amount threshold. To fix this problem and maintain this important incentive for ACOs and other Advanced APM participants, Congress should take swift action to address QP thresholds.”

What’s more, “Nearly 85 percent of survey respondents said the bonus has been ‘extremely important’ to their ACO. When asked how their ACO has used the Advanced APM bonus, the most popular answers were investing in ACO initiatives such as care coordination and data analytics (58 percent) and supporting their ACO’s move to a risk-based model (53 percent). Recruiting more providers and paying existing providers bonuses were also popular responses.”

And NAACOS leaders noted, “During this decade, Medicare spending will top $1 trillion per year. As policymakers look for ways to lower the rate of spending growth, ACOs have become the leading mechanism. In 2019, Shared Savings Program ACOs collectively saved Medicare $2.6 billion, and $1.2 billion after accounting for shared savings bonuses and shared loss payments.”