Keeping up With CMS: Timeline Guides for New and Evolving Alternative Payment Models


Editor’s Note: Sg2 Associate Principal Kristin Oberfeld contributed to this post.

There is a lot happening in traditional Medicare alternative payment model (APM) development and evolution. Sg2 is here to help our members stay on track and think through the strategy to support your organization’s transition to value. Because we recently passed the Bundled Payments for Care Improvement Advanced (BPCI-A) application deadline (June 24) and the Medicare Shared Savings Program (MSSP) notice of intent to apply (NOIA) deadline (June 28), we want to remind organizations of the various programs and their associated deadlines, as well as the opportunity (or lack thereof) for entry. Let’s take a look at…

Medicare Shared Savings Program Pathways to Success

The long-awaited revisions to the MSSP through Pathways to Success are officially effective with July’s new cohort. The notice of intent to apply for a January 1, 2020, start was due June 28, with application window times shown below (keep in mind that the deadlines are at noon ET for this program).

Don’t despair if you missed the NOIA deadline; unlike BPCI-A, there will be additional opportunities to enter the MSSP accountable care organization (ACO) model with the NOIA beginning in May to June of 2020 for entry in January 2021. It is typical in this program to follow a similar annual cadence.

Direct Contracting

CMS’s new model, Direct Contracting, was designed with features of Next Generation ACO (which is no longer accepting new applicants) and Medicare Advantage. Full details are yet to be released, but like the MSSP, you must submit a letter of intent (LOI) by early August.

Even if you are unsure about participation in this program, you should submit the LOI to preserve your option to apply. Jump to our resources list for more.

Bundled Payments for Care Improvement Advanced

The bad news for those who haven’t applied to BPCI-A: the last window to enter the program closed on June 24. However, mandatory episodic models are expected to be released soon (more on that next). For those in the program or those who applied to the program to begin January 1, 2020, some important dates are found below.

More Bundled Payment Models Imminent

CMS has announced new mandatory models through Center for Medicare and Medicaid Innovation. Will there be more coming, potentially voluntary? Be prepared for the new Radiation Oncology (RO) episodic and End-Stage Renal Disease Treatment Choices incentive (ETC) Models. These are still in proposed rule status—with comment period open for 60 days—but it is important to pay attention to whether or not your organization or affiliates are included. RO is expected to start January 1, 2020, or April 1, 2020, while ETC is planned for January 1, 2020. Each will follow a different process for mandatory selection. Sg2 resources on both models are forthcoming.

Emergency Triage, Treat and Transport

This model was announced fairly quietly, and if it gains traction, it could have a profound impact in the communities where it is implemented. Until now, 911 services have only been paid by Medicare to transport patients to the ED. ET3 seeks to reduce unnecessary ED visits and associated costs by partnering with 911 services and their community. Components of the program include triage, treat in place (via on-site or virtual health) and transport to local clinics or urgent care sites. The request for applications (RFA) has already been released, and the portal to submit applications will open later this summer. Keep in mind that this is a multipayer model. Jump to our resources list for more.

Primary Care First

Built on the framework of its predecessor programs Comprehensive Primary Care (CPC) and CPC+ (which is no longer accepting applications), Primary Care First (PCF) is a multipayer medical home model targeted at primary care practices. Historically it hasn’t been available nationwide, but with the rollout of PCF, it will be expanding to additional states and regions. The RFA for a January 2020 start is expected anytime. Historically, CMS has allowed simultaneous participation in CPC+ and MSSP ACOs, though there are crossover implications. More details on crossover with PCF and other APMs should be forthcoming. Jump to our resources list for more.

Next Steps

As shown, there are many active, new and evolving Medicare payment models, and as health systems begin to transition to value-based care, it will be necessary to develop a defined strategy for alternative payment model participation—not to mention coordinate with payers and strategically align with physicians. Sg2 is well-positioned to not only help your organization evaluate your eligibility and readiness for alternative payment model participation, but also evaluate your preparedness for success in a value-based environment.

Please stay tuned for more resources from Sg2 on these APM models! Meanwhile, reach out to our Member Center at 847.779.5500 or to speak to an Sg2 expert about how these new alternative payment models may impact your strategy.

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