Pathways to Success


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The Centers for Medicare & Medicaid Services (CMS) proposed on Aug. 9 an overhaul to the Medicare Shared Savings Program (MSSP), Medicare’s largest value-based payment program, through a proposal which it calls Pathways to Success. Many of the complex changes proposed were the positive result of NAACOS advocacy, such as increased flexibility like choice of assignment methodology, longer, five-year agreement periods, more gradual ramp up of risk, and more waivers like that for telehealth and skill nursing facility stays. However, the proposal includes several challenges like a reduction in shared savings rates, less time in shared savings-only or low risk models distinguishing high and low revenue ACOs, and a +/- 3 percent risk ratio cap applied across five years. The rule can be accessed here along with a related CMS factsheet and press releaseClick the image to the right for our in-depth analysis of the rule, detailing everything ACOs need to know about the proposed changes.  

NAACOS continues to advocate for polices that ensure the long-term success of Medicare ACO programs and educate members on the proposed rule and what it means to them. 

Analysis, Reports and Webinars 

  • NAACOS Review of ACO Pathways to Success Provisions included in the Medicare Physician Fee Schedule Rule 

  • A survey of all current MSSP participants polled ACOs’ feelings about the proposed rule 
    • This NAACOS newsletter article pulls out key points for ACOs.
    • Table 2 from the proposed rule shows new MSSP options 
  • The popular Regulatory Update from the NAACOS fall conference provides another review of the proposed Pathways to Success rule and other policy updates. 
  • NAACOS members and business partners can access our on-demand webinar providing an in-depth review of the proposed rule here
    • A separate webinar breaking down the impact on individual ACOs is available here
  • A one-pager highlights what the proposed Pathways to Success rule means to patients 

News and Advocacy

  • CMS finalizes several MSSP-related policies in the final 2019 Physician Fee Schedule and MACRA rule here. A CMS factsheet is here

  • The November 1 CMS ACO Spotlight Newsletter provides an update on MSSP changes in the 2019 Physician Fee Schedule and Quality Payment Program final rule, including updates on extending contracts that expire at the end of 2018 for another six months. 
  • Lawmakers ask for key changes in final Medicare ACO regulation 
  • NAACOS submitted a 39-page comment letter on the proposed CMS Pathways to Success rule
    • NAACOS press release on its final comments and related ACO poll about proposed Pathways to Success rule 
  • NAACOS member testified before a House subcommittee to discuss the proposed rule 
  • A NAACOS-commissioned study showed ACOs saved Medicare $1.84 billion from 2013 to 2015 
  • Statement on the proposed rule after the initial Aug. 9 release 
  • More Medicare ACOs achieved quality and cost goals in 2017, prompting NAACOS statement; Resource includes highlights of 2017 MSSP results

As we move forward with advocacy efforts surrounding this proposal, it will be critical for ACOs to be active in communicating concerns about the rule with the administration and Congress. A final regulation is expected in late 2018 or early 2019. ACOs are encouraged to share feedback with us on the proposed rule or submit questions to us at [email protected]