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Table 2 from the proposed rule shows new MSSP

options 

 

BASIC Track’s Glide Path

ENHANCED

Track (Current Track 3)

Level A & Level B (one-sided

model)

Level C (risk/reward)

Level D (risk/reward)

 

Level E (risk/reward)

Shared Savings (once MSR met or exceeded)

1st dollar savings at a rate of up to 25% based on quality performance; not to exceed 10% of updated benchmark

1st dollar savings at a rate of up to 30% based on quality performance, not to exceed 10% of updated benchmark

1st dollar savings at a rate of up to 40% based on quality performance, not to exceed 10% of updated benchmark

1st dollar savings at a rate of up to 50% based on quality performance, not to exceed 10% of updated benchmark

No change. 1st dollar savings at a rate of up to 75% based on quality performance, not to exceed 20% of updated benchmark

Shared Losses (once MLR met or exceeded)

N/A

1st dollar losses at a rate of 30%, not to exceed 2% of ACO participant revenue capped at 1% of updated benchmark

1st dollar losses at a rate of 30%, not to exceed 4% of ACO participant revenue capped at 2% of updated benchmark

1st dollar losses at a rate of 30%, not to exceed the percentage of revenue specified in the revenue-based nominal amount standard under the Quality Payment Program (for example,

8% of ACO participant revenue in 2019 – 2020), capped at a percentage of updated benchmark that is 1 percentage point higher than the expenditure-based nominal amount standard (for example, 4% of updated benchmark in 2019 –2020)

No change. 1st dollar losses at a rate of 1 minus final sharing rate (between 40% - 75%), not to exceed 15% of updated benchmark

 

 

 

 

 

 

1

 

BASIC Track’s Glide Path

 

ENHANCED

Track (Current Track 3)

Level A & Level B

(one-sided model)

Level C (risk/reward)

Level D (risk/reward)

Level E (risk/reward)

Annual choice of beneficiary assignment methodology? (see section II.A.4.c)

Yes

Yes

Yes

Yes

Yes

Annual election to enter higher risk? (see section II.A.4.b)

Yes

Yes

No; ACO will automatically transition to Level E at the start of the next performance year

No; maximum

level of risk / reward under the BASIC track

No; highest level of

risk under Shared Savings Program

Advanced APM status under the Quality Payment Program? 1, 2

No

No

No

Yes

Yes

 

Notes: 1 To be an Advanced APM, an APM must meet the following three criteria: 1. CEHRT criterion: requires participants to use certified electronic health record technology (CEHRT); 2. Quality Measures criterion: provides payment for covered professional services based on quality measures comparable to those used in the quality performance category of the Merit-based Incentive Payment System (MIPS); and Financial Risk criterion: either (1) be a Medical Home Model expanded under CMS Innovation Center authority; or (2) require participating APM Entities to bear more than a nominal amount of financial risk for monetary losses. See, for example Alternative Payment Models in the Quality Payment Program as of February 2018, available at https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Comprehensive-List-of-APMs.pdf.

2 As proposed, BASIC track Levels A, B, C and D would not meet the Financial Risk criterion and therefore would not be Advanced APMs. BASIC track Level E and the ENHANCED track would meet all three Advanced APM criteria and thus would qualify as Advanced APMs. These preliminary assessments reflect the policies discussed in this proposed rule. CMS will make a final determination based on the policies adopted in the final rule.