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               NAACOS Analysis Shows ACOs In Top MIPS Performance Tier 

The National Association of Accountable Care Organizations (NAACOS) is sharing results of its analysis of ACO performance in the Quality Payment Program (QPP) of the Merit Based Incentive Payment System (MIPS) created under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Working with NAACOS, the firm of Dobson | DaVanzo modeled the Alternative Payment Model (APM) scoring standard rules applicable to ACOs in MIPS and applied historical Track 1 ACO quality data to project 2017 ACO MIPS scores and their corresponding payment adjustments in MIPS. The analysis found that all 2017 Track 1 ACOs are likely to score well above the MIPS performance threshold, and most above the MIPS exceptional performance threshold, thereby receiving a positive MIPS payment adjustment. However, the overall ease at which MIPS clinicians may earn positive adjustments, coupled with budgetary restraints, indicates that most payment adjustments may be relatively small, ranging from 0.4 percent to 2.6 percent of qualified providers’ Part B expenditures. For more information on how ACOs are scored in MIPS, please refer to our ACO Guide to MACRA. 

ACOs commitment to quality improvement is clear. An August 2017 HHS Inspector General’s report also found that Medicare ACOs improved performance on 82 percent of individual quality measures compared to their baseline and outperformed fee-for-service providers on 81 percent of quality measures. This analysis is further proof that ACOs’ hard work and dedication to quality improvement is paying off and should be rewarded by CMS. More detailed information about the analysis is included below. 

Key Findings

  • All 2017 Medicare Shared Savings Program (MSSP) Track 1 ACOs included in the analysis are projected to earn a positive MIPS payment adjustment.
  • The vast majority of 2017 MSSP Track 1 ACOs are projected to surpass the secondary MIPS scoring threshold for increased positive payment adjustments under most scoring scenarios tested.
  • After applying CMS example scaling factors, the analysis projects ACOs would earn between a 0.4 percent and 2.4 percent positive payment adjustment under MIPS. 

Key Assumptions

  • The analysis modeled the MIPS scoring methodology for the following performance categories:
    • Quality Performance Category – Using ACO quality scores from PY2015 (the most recent available), utilizing PY2017 ACO benchmarks for MIPS.
    • Improvement Activities Performance Category – Per CMS guidance, all ACOs will receive the maximum score automatically.
    • Advancing Care Information Category (ACI) – The analysis made two main assumptions on ACO performance to create a range of possible outcomes: under the most optimistic scenario, the analysis assumes full credit is earned in the ACI performance category; under the most pessimistic scenario, the analysis assumes the ACO achieved the Base Score criteria of ACI.
  • The analysis modeled the MIPS payment adjustment methodology using the following assumptions:
    • Based on the combined scores and the score thresholds for a potential positive payment adjustments projected by CMS in the QPP final rule, the analysis determined the payment adjustments under three performance scenarios: most optimistic, intermediate (an average of the most optimistic and most pessimistic projections), and most pessimistic.
    • Payment adjustments were reduced by ‘scaling factors’ for budget neutrality purposes as required by statute, relying on the scaling factors given as an example in the QPP final rule.
  • MIPS payment adjustment projections were made for 264 out of 392 MSSP participant ACOs in 2015. 

Analysis of Key Findings 

CMS has established a 3-point minimum performance threshold and a 70-point exceptional performance threshold for the 2017 performance year. Under the most optimistic assumptions, all ACOs met or exceeded the exceptional performance threshold and would be eligible for maximum bonuses under MIPS. 

Under the intermediate assumptions, all ACOs would score greater than 60 points, thereby earning bonuses and avoiding penalties under MIPS. However, only those scoring greater than or equal to the 70-point exceptional performance threshold would be eligible for the additional, exceptional performance bonus. 

Under the most pessimistic assumptions, all ACOs earn greater than 50 points and would avoid a penalty and earn bonuses under MIPS. 

Given the low minimum performance threshold established by CMS for the 2017 performance year, even those earning the highest scores in MIPS will be eligible for only minimal bonuses given the program’s budget neutrality requirements. In the most optimistic scenario, even those scoring a perfect score would be eligible for a meager 2.4 percent bonus in MIPS. 

Under the intermediate assumptions, bonuses would range between .5% and 1.9%. 

Under the most pessimistic assumptions, bonuses would range between .4 percent and 1.3 percent. 

Additional Notes on Methodology:

  • The weights for the MIPS performance categories under the APM Scoring Standard, as applicable to ACOs, were utilized: Quality (50 percent), Improvement Activities (20 percent), and ACI (30 percent). For performance year 2017 the Cost category has 0 percent weight
  • MIPS payment adjustment projections are calculated for MSSP Track 1 ACOs, which by definition are the only APM under the MSSP that is required to participate in the MIPS
  • For the Quality Performance Category (50 percent):
    • In scoring Quality, the analysis used 2015 MSSP performance scores (the most recently available quality performance data for MSSP ACOs).
    • The analysis only included current (2017) Track 1 ACOs, based on the 2017 CMS MSSP Organizations list.
    • The analysis excluded ACOs that did not report quality data in 2015.
    • Based on these exclusions, projections were made for 264 out of 392 MSSP participant ACOs in 2015.