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Implications for Physician Compensation
Accountable Care Organizations (ACOs) are anticipated to play a significant role in the future landscape of healthcare. It is important to understand what their existence may mean in regards to the direction of impending cost containment strategies. More pertinent to INTEGRATED, is the impact these ACOs may have on the future of physician incentives and compensation. This paper is intended to share an investigation and findings with you, in the hope that it provides you with some additional insights and considerations about ACOs.
Background
An ACO is defined by the Centers for Medicare and Medicaid Services (CMS) as:
“…groups of doctors, hospitals, and other health care providers, who come together voluntarily to give coordinated high quality care to their Medicare patients. The goal of coordinated care is to ensure that patients, especially the chronically ill, get the right care at the right time, while avoiding unnecessary duplication of services and preventing medical errors. When an ACO succeeds in both delivering high-quality care and spending health care dollars more wisely, it will share in the savings it achieves for the Medicare program.” (Centers for Medicare and Medicaid Services, 2014).
The concept of a provider and a payer sharing in healthcare savings is nothing new. In one context or another, Health Maintenance Organizations (HMOs) have relied on this concept since at least the 1980s. The most recent adaptation however, began to take its current shape between 2005-2009 with a federal demonstration project called the Medicare Physician Group Practice Demonstration, which focused on physician groups serving dual eligible Medicare and Medicaid patients and tied bonus payments directly to patient care quality and cost reduction metrics. The results of the demonstration projects were an average of 4-5% cost reduction per person to CMS (Colla, 2012), which served as the catalyst for the inclusion of an ACO program into the structure of the Patient Protection and Affordable Care Act of 2010 (PPACA).
Implementation
The ACO framework laid out by the PPACA commenced with two pilot programs based upon the fundamental difference in risk assumption between the payer and provider. The first pilot, called the Medicare Shared Saving Program (MSSP), is a one-sided shared savings program that financially rewards providers with a percentage of the savings
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financial yield in the MSSP program is capped at a lower rate. The second pilot, called the Pioneer ACO Program, is a shared risk program in which the provider becomes financially liable for incurred losses but also enjoys a greater share of the financial reward in any accrued savings.
ACO participants must have a minimum of 5,000 enrolled (assigned) beneficiaries (Gold, 2014), primarily to dampen the spikes in average weighted cost from acute catastrophic episodes. Savings are determined by performance and quality metrics in as many as 33 different categorical parameters in an undisclosed mathematical algorithm. Minimum Savings Rate thresholds exist within the framework of the agreement to safeguard the payer and are applicable under both programs before any savings are divided and redistributed. Minimum Savings Rates for the shared risk Pioneer program are 2% and Minimum Savings Rates in the risk-free MSSP program balloon to 3.9% (Bailit & Hughes, 2011).
The commencement of the MSSP program had 114 participants. Of these, “54 were able to keep costs below their budget benchmark, but only 29 were able to hold down costs enough to qualify for shared savings. These successful ACOs received $126 million in savings, while the CMS trust fund realized savings of $128 million, around 1 percent of costs. The other 60 MSSP ACOs experienced spending above their set benchmark.” (McClellan & White, 2014).
The commencement of the Pioneer program had 32 participants, “generating $147 million in total savings, with approximately $76 million in savings returned to the ACOs and $69 million returned to Medicare, around 2% of costs. Of the original 32 Pioneer ACOs, 12 qualified for shared savings, one shared in losses, and 19 did not share in savings or losses.” (McClellan & White, 2014).
Both of these CMS ACO programs continue to operate under their inaugural contracts, which commenced with the ratification of the PPACA phase 2 on January 1, 2014 and will conclude on December 31, 2016.
Private Sector Interest
The opportunity to reap financial reward has of course, attracted the interest of the private sector. Privately contracted ACO models are subsequently becoming commonplace in the healthcare market between private insurers and providers. Preliminary (and cursory) data indicates that a properly equipped and integrated health provider network is capable of generating considerable savings under this model, thereby reaping significant financial reward. Subsequently, the market curiosity in private sector ACO models is drawing favorable interest - even though many potential
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Because of the scope of health management integration necessary to accrue tangible savings (and thereby justify the existence of the program), it is unlikely, if not impossible, for small physician groups to participate in ACOs without assimilating into larger health networks. ACO critics warn that this may encourage more healthcare mergers and takeovers, whereas proponents argue that mergers and takeovers are already commonplace despite the inclusion of the ACO model.
One of the primary obstacles for small physician groups in joining or becoming an ACO is the tremendous startup cost for creating or upgrading a distributed system of information management that integrates electronic medical records into electronic health records, utilizing a universal system nomenclature that allows for more efficient processing and communication between different types of healthcare specialties and entities. The PPACA contains language that provides financial assistance for rural and/or destitute healthcare networks in order to upgrade their infrastructure for the ACO transition. However, there is no precedence for what will happen to these networks if they default on their federal loans in the event of implementation failure, administrative gridlock, or both.
Plausible Speculations
Since ACO’s assume additional administrative burden, it would be reasonable to assume that some of the pioneer programs were initially unsuccessful due to the time and monetary constraints associated with the considerable operational, procedural, and information management restructuring necessary to accommodate the expedited delivery systems. It would also be reasonable to assume that these dramatic and necessary changes in health network operations could create enough inefficiency per se to push a new ACO participant into the minimum savings rate of the payer, yielding little or no shared savings for the first year. Again, large provider networks are in an advantageous position in this regard with a higher likelihood of operational stability and infrastructure, along with the managerial time and talent that is available to them in execution. It will be interesting to see if the next few years of data will showcase a financial savings swing as participating ACO health networks iron out their own internal operational kinks within the framework of the system.
Despite what appears to be an obvious attempt to withhold actual dollar values from public view, total savings figures are available for the CMS ACO pioneer groups as a whole. The individual success of each participating provider is obscured, along with how these savings returns were apportioned between physician incentive and net income to the organization for the administration of the program. Physicians may be compensated for their efforts up to their fair market value (FMV). But, it is unclear how
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Statutes. The Stark Law’s Group Practice Exception provides leeway in self-serving physician referrals within provider networks, but loosely cobbled together ACOs may not qualify for this protection by definition in the private sector.
Switching to an ACO model changes the landscape of physician compensation incentives by initially delaying payouts for up to 15 months. Meaning, care quality metrics would take an entire fiscal or calendar year to accrue, then as much as another quarter to interpret, reconcile, and payout these earned incentive amounts. At first, these incentive payments are likely to represent a relatively small percentage of a provider’s compensation package. As ACO and other performance-based programs grow and mature, we could safely speculate that a physician would only earn their base draw or some portion of his or her total cash compensation during the operating year only to wait for the rest of their compensation once incentives are determined. This would act as a catalyst for significant pushback against an ACO implementation by employed physicians.
It is reasonable to expect that providers could be asked to work harder for the same or less initial compensation, with the anticipation of incentive payouts at the end of a year. Providers will be very unhappy and demoralized if after working harder, incentive payouts do not materialize. Dissatisfaction over pay v. working conditions could potentially raise the appeal of organized labor.
Conclusion
Public and private sector ACOs will continue to change and develop for years to come. The CMS sponsored programs will continue at least until the end of 2016. Regardless of whether or not the program is renewed on a federal level, it is inevitable that the ACO concept will continue to perpetuate in the private sector in some form or another. Now that the financial precedence exists, the ability to generate savings through efficiency in infrastructure will certainly remain a viable option for any private business model. This “carrot-and-stick” approach to shared savings is a powerful negotiating tool between payers and providers because of its ability to create a mutually beneficial financial relationship. As physician incentive and compensation consultants, we must carefully consider the ramifications of these programs in what we do.
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Bailit, M., & Hughes, C. (2011). Key Design Elements of Shared Savings Payment Arrangements. The Commonwealth Fund, 1-16.
Centers for Medicare and Medicaid Services. (2014, July 11). Accountable Care Organizations. Retrieved from cms.gov:
http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/ACO/ Colla, C. H. (2012, September 12). Spending Differences Associated with The Medicare
Physician Group Practice Demonstration. Retrieved from The Journal of the American Medical Association:
http://jama.jamanetwork.com/article.aspx?articleid=1357260
Gold, J. (2014, April 16). FAQ On ACOs: Accountable Care Organizations, Explained. Retrieved from Kaiser Health News:
http://www.kaiserhealthnews.org/stories/2011/january/13/aco-accountable-care-organization-faq.aspx
McClellan, M., & White, R. (2014). Issue Brief: How to Improve the Medicare
Accountable Care Organization (ACO) Program. Engelberg Center for Health Care Reform at Brookings , 1-10.
Muhlestein, D. (2013, October 31). Why Has ACO Growth Slowed? Retrieved from Health Affairs: http://healthaffairs.org/blog/2013/10/31/why-has-aco-growth-slowed/
Issue Brief
Key Design Elements of
Shared-Savings Payment Arrangements
M
ichaelB
ailit andc
hristineh
ughesB
ailith
ealthP
urchasing, llc
ABSTRACT: Shared savings is a payment strategy that offers incentives for providers to reduce health care spending for a defined patient population by offering them a percentage of net savings realized as a result of their efforts. The concept has attracted great interest, in part fueled by Affordable Care Act provisions that create accountable care organizations and by the movement among medical home pilots to make payment methodologies more performance-based. In this issue brief, the authors interviewed payer and provider orga-nizations and state agencies involved in shared-savings arrangements about their diverse approaches, including the populations and services covered, the assignment of providers, the use of risk adjustment, and the way savings are calculated and distributed. The authors identified issues payers and providers must resolve going forward, including determining whether savings were achieved, equipping providers with necessary tools and technical advice, agreeing upon standard performance measures, and refining the model over time.
OVERVIEW
Shared savings is a payment strategy that offers incentives for provider entities to reduce health care spending for a defined patient population by offering them a percentage of any net savings realized as a result of their efforts. Shared sav-ings can be applied to some or all of the services that are expected to be used by a patient population. The concept has attracted great interest in 2011, in part fueled by provisions within the Patient Protection and Affordable Care Act that create accountable care organizations (ACOs).
Specifically, the creation of the Medicare Shared Savings Program for ACOs, beginning in 2012, calls for shared savings as a primary payment method-ology. This prompted frenzied activity among many providers to position them-selves to become ACOs even before the draft rules for the program were released. Such provider organizations have taken steps to negotiate and implement shared-savings contracts with commercial insurers.
To learn more about new publications when they become available, visit the Fund's Web site and register to receive e-mail alerts.
Commonwealth Fund pub. 1539 Vol. 20
For more information about this study, please contact:
Michael Bailit, M.B.A. Bailit Health Purchasing, LLC mbailit@bailit-health.com
The mission of The Commonwealth Fund is to promote a high performance health care system. The Fund carries out this mandate by supporting independent research on health care issues and making grants to improve health care practice and policy. Support for this research was provided by The Commonwealth Fund. The views presented here are those of the authors and not necessarily those of The Commonwealth Fund or its directors, officers, or staff.
Added interest in shared savings comes from the movement among medical home pilots to make payment methodologies more performance-based. A few early pilots have employed shared-savings approaches and others are developing or implementing plans to do so.1
Shared savings is not a wholly new reimburse-ment model. While it has not been widely used, there are existing examples of the concept in operation that predate the Affordable Care Act. Examining the char-acteristics of these models may increase understanding regarding how best to structure shared-savings arrange-ments and the decisions faced in constructing them.
In this issue brief, Bailit Health Purchasing conducted 32 telephone interviews with payer and pro-vider organizations and state agencies that indicated they were involved in independent past, current, and planned shared-savings payment arrangements. The 27 assessed shared-savings programs were primarily applied in primary care practice medical home pro-grams and in ACO-like payment arrangements involv-ing a more broadly defined provider organization. Approximately one-third of the arrangements were formed through medical home or medical home-like programs. The medical home and ACO-like shared-savings models did not differ considerably in construc-tion beyond medical home programs providing supple-mental PMPM payments and ACO-like programs that did not. Approximately two-thirds of the arrangements were implemented in 2010 or 2011.
There are a few key issues which payers and providers must resolve as they design and implement shared-savings payments models. First, they must agree on how to determine whether savings were achieved so that there is both a meaningful incentive for the provider and reasonable protection that calcu-lated savings do not reflect random variation in health care costs. This balance is difficult to achieve, espe-cially in the case of smaller provider organizations.
Second, providers need tools to succeed if they are to transform care delivery. Payers can help provide some of these tools, including timely, trended perfor-mance data with targets and benchmarks, and giving
practices the ability to manipulate such data. They can also provide technical advice regarding knowledge and implementation of systems and processes to deliver better care more efficiently. In particular, smaller pro-vider organizations may need additional assistance, as well as those that are not in robust financial health.
Third, while testing the application of varied performance measures across payers may be of value in the near term, competing sets of performance mea-sures in shared-savings methodologies could eventu-ally harm the effectiveness of the payment models, as providers will find it difficult to focus. There may be opportunities for regional coalitions to identify a com-mon framework with which nonfederal payers might align.
Finally, national expectations are high that payment and delivery system reform will finally slow the inexorable march of health care cost growth. It will be necessary to learn within and across both payer and provider organizations from the successes and failures and to maintain a resolve to persistently refine the shared-savings payment model to maximize effective-ness.
PATIENTS, SERVICES, AND PAYMENTS IN
SHARED-SAVINGS MODELS
Which patient populations are included in
shared-savings models?
Shared-savings arrangements vary in terms of included patient populations, depending on whether the arrangements are applied in medical home models or ACO-like models. Medical homes tend to include fully insured commercial populations in single-payer models, and fully insured commercial populations and Medicaid managed care populations in multipayer initiatives. Patients covered by self-insured employers are included under some arrangements but not others. This is because of the varying policy positions taken by third-party administrators regarding charging self-insured employers the supplemental per member per month (PMPM) payments usually made to practices under medical home pilots. Specifically, some admin-istrators believe their administrative agreements with
self-insuring employers allow for supplemental pay-ments to medical homes while others do not. In cases where the supplemental payments are not considered permitted under the administrative services agreement, some third-party administrators will ask self-inured employers to opt-in to such payments, some will invite employers to opt out, and others will not broach the subject with their self-insured employers. Finally, some administrators will treat different classes of self-insur-ing employers differently.
ACO-like shared-savings models, which do not routinely provide PMPM supplemental payments, are much more likely to include patients covered under self-insured employer contracts. These ACO-like shared-savings models are applied to a variety of dif-ferent patient populations, most often including the following:
• only commercially insured and self-insured; • only Medicare Advantage;
• commercially insured, self-insured, and Medicare Advantage, and
• traditional Medicare and/or Medicare/
Medicaid dual eligibles (in the context of CMS federal demonstrations).
In some cases the payer begins the shared-savings program with one patient population and then expands to other patient populations in future years. Medicaid populations were rarely involved in the ACO-like shared-savings models, but were involved in medical home shared-savings models.
Finally, pediatric populations are excluded in some instances. This can be because of payer concern that the opportunities for savings, particularly in com-mercially insured populations, are not great due to the generally good health status of children.
How are providers assigned responsibility for
the patient population for which savings are
calculated?
For patients enrolled in a PPO product or in traditional Medicare, the patient population in almost all instances
is defined by the use of a patient-attribution methodol-ogy that examines historical utilization patterns and attributes the patient to the provider entity with which the patient has the best-established care pattern. The pattern is typically assigned by determining with which practices the patient had the most primary care visits, or primary and specialty visit, for specified evalua-tion and management codes in the past 12, 18, or 24 months. In some cases, consideration is also given to the most recent visits, particularly in the event of a tie in the number of visits. The attribution is performed by the payer using the claim data.
For patients enrolled in an HMO product, the responsible provider is the provider entity with which the patient’s selected primary care clinician is affiliated.
On occasion, shared-savings models will assess performance only for those patients who were continuously enrolled for 11 or 12 months of the year.
What services are included in the shared-
savings calculation?
Most of the studied shared-savings programs assess savings relative to the full set of covered services for the patient population. These services vary depending upon the payer and the line of business; for example, commercial plan, Medicare Advantage, traditional Medicare, and Medicaid. There are programs that exclude certain services, however. Examples of excluded services include: organ transplants; prescrip-tion medicaprescrip-tions; behavioral health; pediatric services; dental services, except for limited services covered by health care coverage premium payments; out-of-area services; and nonpreventable inpatient and emergency department services.2
In some cases services are excluded because self-insured employers will carve services out to a specialty vendor (e.g., pharmacy), making the shared-savings calculation more challenging to perform because the benefit is administered by the insurer for some members and not others. One carrier interviewed for this study described a method to adjust for such carve-outs.
In multipayer medical home arrangements that utilize multipayer claims databases, limitations to databases can potentially limit the services that are included. For example, Maryland’s multipayer database does not always contain pharmacy claim information.
What payments are excluded from the
shared-savings calculation?
In addition to excluding certain patient populations and services, shared-savings arrangements commonly exclude certain types of payments. Such payments include the following categories:
Non–service-related payments. Shared-savings arrangements will exclude consideration of payments that do not relate to the direct provision of services, including:
• performance incentive payments, such as pay-for-performance bonuses;
• management fees;
• vendor-capitated payments (e.g., behavioral health, laboratory); and
• risk-contract settlements (including prior year shared-savings payments).
High-cost outliers. Shared-savings arrange-ments commonly remove costs related to patients with very high costs during the measurement period, which is typically 12 months. This is done by truncating the high-cost patients. The payer and provider entities define an annual per-patient expenditure level above which any medical expense will be either fully or par-tially excluded from the shared-savings calculation.
The dollar level at which patient-specific medical expense is truncated varies considerably. In most cases it is defined as a flat dollar amount, with an observed range of $50,000 per year to $500,000 per year. The most commonly reported truncation points were between $100,000 per year and $200,000 per year. Medical home model truncation points tend to be somewhat lower than those of the ACO-like arrangements.
While the flat dollar truncation approach is most common, there are other approaches to address-ing high-cost patient outliers, includaddress-ing:
• making no adjustment;
• defining the truncation point in terms of standard deviation from the mean per patient annual medical expense, such as two and three standard deviation truncation points;
• varying the truncation point by patient popula-tion (e.g., commercially insured vs. Medicare Advantage) due to different patterns in spend-ing by population;
• applying some percentage medical expense above the truncation point to the shared-saving calculation in order to motivate the provider to continue to engage in care management after the patient exceeds the threshold; and
• truncating based on utilization measures rather than cost measures (e.g., costs associated with inpatient stays in excess of 20 days).
In cases in which high-cost medical expenses are truncated, the payer either removes the value of those claims from the target being used for savings calculation or the payer “charges back” the cost of reinsuring the provider for purposes of shared-savings calculations.
Finally, on rare occasions, low-cost outliers are also excluded for the savings calculation. The impli-cation of this practice on savings determinations is unclear.
How are supplemental payments and
vendor-capitated payments treated in shared-savings
calculations?
Supplemental PMPM payments are common in medical home payment models. These payments are typically netted out as expenses in shared-saving calculations.
Vendor-capitated payments for services such as behavioral health or laboratory services are treated in one of two ways. The payments and associated
services may be excluded altogether from the calcula-tion. Alternatively, encounter data submitted by the capitated vendor can be priced per unit of service and included in the calculations.
SPECIAL ADJUSTMENTS TO
SHARED-SAVINGS CALCULATIONS
Do shared-savings calculations involve risk
adjustment?
Only about half of the studied models employed risk adjustment, with a few contemplating risk adjust-ment in the future. Those models that do employ risk adjustment use four different models: the Center for Medicare and Medicaid Services’ (CMS) hierarchical condition categories methodology; the Prometheus payment methodology; or one of two leading com-mercial risk-adjustment software packages, the Johns Hopkins’ adjustedclinical groups case-mix system and the Verisk Health Sightlines DxCG risk solutions product.
Models electing not to use risk adjustment were more likely to be medical home initiatives or believed that risk adjustment was not imperative because the shared-savings model involved compar-ing the provider’s performance to its own past perfor-mance, with an assumption that the patient population risk burden would not vary much from year to year.
What in-kind or other supports do payers
sup-ply providers operating under shared-savings
arrangements, and how are these treated in the
calculation of savings?
Payers vary considerably in their approaches to sup-porting providers operating under shared-savings arrangements. In the vast majority of cases, support is provided at no cost to providers. Only two payers interviewed for this study reported they charged pro-viders for support. The value of the support was never reported to be netted out of any savings.
The primary form of payer support is the pro-vision of reports and data, including:
• claim files for provider manipulation and analysis; these are most commonly desired by
large provider organizations with the resources to maintain a sophisticated internal analytic function and that are seeking an alternative to multiple independent reports from different payers;
• access to a payer database with software tools that provide standard reports and allow for cus-tomized inquiries;
• a suite of patient attribution, utilization, cost reports, made available most often through a payer’s Web portal; and
• ad hoc analyses at the provider organization’s request.
In several instances payers provide by consul-tation physicians, nurses, or other payer staff to provid-ers on the interpretation and applied use of data and reports. Assistance and consultation in delivery system redesign and practice transformation is less common and takes the following forms:
• learning collaborative or primary care prac-tice coaching, primarily in medical home initiatives;
• care management training, both practice-based and inpatient;
• roundtables and forums for provider organiza-tions to exchanges ideas and best practice; and • hospital admission and emergency department
notification.
ACHIEVING ACCEPTABLE CONFIDENCE IN
SAVINGS CALCULATIONS
What is the minimum size of a provider’s panel
of patients to participate in the shared-savings
arrangement?
Shared-savings arrangements vary significantly in terms of the minimum number of patients for whom a provider must care. While some studied models set no patient population minimum, either because they purposely elected not to or, more often, because they
involve very large provider organizations only, mini-mum patient populations are often required to ensure that savings calculations can capture savings with some degree of confidence of accuracy. Payers can be reluctant to enter into a payment model in which they may make additional provider payments that are not “real,”—that is, they may be the result of random vari-ation. This is especially true because shared-savings arrangements by definition pose no downside risk to the participating providers. While adjustment for high-cost outliers removes some degree of random variation in health care costs, it does not adjust for it all. Also, this high-cost outlier adjustment provides some protec-tion to providers, but does not address the source of greatest concern to some payers—paying bonuses for random variation that produces low costs.
This issue is relevant for both ACO-like and medical home shared-savings arrangements, although sometimes more challenging for the latter because the participating provider entities have tended to be smaller.
For commercially insured populations, required minimum patient populations varied from 1,000 to 10,000. For Medicare patient populations (traditional Medicare and Medicare Advantage), the required minimum patient populations ranged from 333 to 5,000. The latter figure is the minimum proposed by CMS for the Medicare Shared Savings Program. In one case, the thresholds were defined for the total provider patient population and savings calculated for all par-ticipating payers for commercial, Medicare Advantage, and Medicaid managed care.
Shared-savings methodologies that are ser-vice-focused rather than population-focused, such as Prometheus Payment and the Medicare Acute Care Episode Demonstration also set minimum thresholds. In the latter case the threshold was set for providers to qualify for the demonstration.
The variation in approaches to setting mini-mum population sizes is a result of differences of opin-ion among actuaries and statisticians and differences in business strategy by payer executives in three key areas:
• the level of statistical certainty produced by different population sizes;
• the risk tolerance of payers relative to different levels of certainty and uncertainty; and
• the relative priorities set by a payer when con-sidering goals relative to statistical delivery. One interviewee observed, “The fundamental question is whether the main purpose of shared savings is to incentivize the practices to change or to accurately reward practices for their efforts.” Another interviewee commented that at his health plan’s minimum thresh-old there was still much practice cost volatility, and he knew that his actuaries would have preferred a much higher number than that which the insurer adopted. If he had done what the actuaries wanted, there would not be many groups with shared-savings arrangements.
Designers of shared-savings models face important trade-offs, especially if they want to apply shared-savings models to smaller provider entities or to provider entities with which a given payer may have coverage responsibility for a relatively small percent-age of the provider’s patients.
How else do payers protect themselves against
paying for savings that may not be “real?”
In some instances, payers have taken an additional risk protection step beyond minimum patient population thresholds. This involves the payer retaining some per-centage of initial savings before sharing any additional savings with the provider. In the CMS Physician Group Practice Demonstration, if savings were 2 percent or less of the value of the estimated budget, CMS would make no bonus payments. Practices would only begin to share savings above that level and then up to a maxi-mum of 5 percent. This type of cap is a component that generally was not found in commercial payer models. In two other models the retained percentage before sharing savings was 2 percent; in a third model, it was 5 percent; and in a fourth model, the participants would not disclose the percentage.For the Medicare Shared Savings Program, CMS proposes to set a minimum savings rate (MSR) that an ACO must exceed to share in savings. The MSR is defined by both the number of assigned beneficiaries and a CMS-chosen confidence interval. The percentage of savings that must be realized before any are shared with the provider are still far greater for smaller ACOs than for larger ACOs. For example, an ACO with 5,000 Medicare beneficiaries would need to save at least 3.9 percent before any savings would be shared, while an ACO with 60,000 Medicare beneficiaries would be required to save at least 2 percent before any savings were shared. This contrasts with the majority of com-mercial payer models that have no minimum savings rate or utilize a flat percentage.
CMS requires that the savings exceed the MSR before savings are shared, but it will then share savings after the first 2 percent. There are exceptional circum-stances—not found in any of the other studied mod-els—when the 2 percent requirement is waived.3
In some models there is purposely no payer-retained savings because the savings are calculated for a service, rather than for a population. In these cases the payment rate for a specific service was discounted up front so that the payer automatically sees some sav-ings prospectively.
What strategies have been adopted for
provid-ers that fall below the minimum patient
vol-ume thresholds?
The shared-savings cases in this study typically fol-lowed one of three courses of action with regard to the involvement of smaller provider entities in shared-sav-ings arrangements when minimum population thresh-olds were not met.
1. Most commonly, the payers would exclude from eligibility those providers whose patient population fell below the payer’s established threshold, although in a few instances excep-tions were made.
2. In some cases payers combined small-provider entities into a pool with other providers to
meet the threshold. Should the pool of provid-ers earn savings, the savings are then be allo-cated across those providers that composed the group.
3. In a couple of instances, pooling was done for all participating providers.
Providers tend to argue against pooling or aggregating, as it results in a perceived loss of control and motivation. Some argue that pooling of all partici-pating providers so dramatically reduces control that it is inconsistent with common understanding of shared savings. Providers appear to only support pooling if it is done across entities that have a preexisting contrac-tual or organizational relationship.
In instances when pooling occurs, there are questions about how it is structured. Options include pooling providers by geographic proximity, organiza-tional type, providers’ primary specialty (for medical homes), patient mix, and baseline performance.
CALCULATING SAVINGS
How does the model determine if savings
were achieved?
A basic question for any shared-savings model is the method for determining whether the provider’s efforts achieved any savings. Savings are typically assessed for a 12-month measurement period. Models typically assess savings in two ways:
Comparison of provider-associated cost to a budget or target. Under this arrangement, the payer considers the past costs associated with the provision of care to the provider-attributed patient population and projects forward future costs. Such forecasting may take into account projected general medical trends, changes in benefit plan design, and planned cost con-tainment strategies to be implemented by the payer. The cost budget can be subject to negotiation, with one payer comparing the process to a rugby match.
Approximately two-thirds of the studied mod-els use a budget or target approach. In at least one instance the target was informed by looking at best
practice in the region and using those data, in part, to set the target.
The proposed Medicare Shared Savings Program uses a target or benchmark approach. As stated in CMS materials, “CMS would . . . develop a benchmark for each ACO against which ACO perfor-mance is measured to assess whether it qualifies to receive shared savings . . . . The benchmark is an esti-mate of what the total Medicare fee-for-service Parts A and B expenditures for ACO beneficiaries would other-wise have been in the absence of the ACO.”4 CMS
pro-poses setting its benchmark based on claims data from the previous three years for beneficiaries who would havebeen assigned to the ACO, with the most recent years weighted most heavily and adjustments made to account for the increase in national Medicare fee-for-services expenditures.
Comparison to a control group. In some cases the rate of change in the PMPM costs of patients attrib-uted to a provider are compared with those of either a select comparison group or to the payer’s full regional provider network (otherwise known as “book of busi-ness”), with the provider included or excluded from the book-of-business calculation. If the provider’s trend rate falls below that of the control group, the difference in trend rates is used to calculate the amount of the sav-ings. In some cases the control group is negotiated and in other cases it is defined by the payer.
There are some additional variations with regard to the implementation of these two approaches:
• Savings can be calculated by comparing the PMPM costs of patients attributed to a pro-vider to the prior year experience, without any comparison to a control group.
• Both the budget and the control group trend comparison can be calculated using a subset of services rather than something approximating or equally total medical expense. For example, the model can consider only expenses related to inpatient hospital use and emergency depart-ment service use, since these two areas are usually considered to be two primary sources
of savings. It can also consider trend rates for only patients with chronic conditions for whom cost savings opportunities may be greatest. Those who support the budget approach say that its strength is allowing providers to know what needs to be achieved. Its detractors note the perilous nature of forecasting medical trends for purposes of establishing a budget, noting the impact of unantici-pated events such as flu epidemics and sudden changes in the economy.
Those who support the control group approach note that it protects against external factors that sig-nificantly drive medical expense trends and uses real, rather than projected, figures to assess savings. Its detractors observe that control groups are not always easily defined (and will become less so as payment reform expands) and that the computations to ensure true comparability—including possible adjustments for case mix, changes in product mix, provider contract rates, and geographic factors—can be complex.
DISTRIBUTING SAVINGS
For what percentage of savings are providers
eligible?
Shared-savings models take many different approaches toward allocating savings between the provider and the payer. For multiprovider entities, there are further met-rics for allocation of savings among the providers.
The most common distribution of provider and payer net savings is 50 percent to the provider and 50 percent to the payer.5 As discussed further below, in
many cases the provider percentage is contingent on acceptable or strong performance on a set of measures. While a 50/50 split arrangement is most common, there are many other approaches, including:
• the provider earning more than 50 percent, with percentages rising to 65 percent and even 80 percent;
• the precise provider share can be determined by the provider’s nonfinancial performance using a set of measures, with the distribution
of savings scaled from 0, 20 percent, or 40 percent.
• providers can earn a flat percentage, but the total dollars shared can be capped; for exam-ple, in one arrangement the payer shares sav-ings up to 6 percent after an initial 2 percent payer retention. With a 50/50 split, the most the provider can earn is 3 percent of the budget amount; and
• in the Prometheus Payment model, the payer takes its savings out of the bundled payment and then the provider earns whatever savings it can generate from the discounted payment. As is the case with other shared saving design elements, the percentage of savings for which each party is eligible is often subject to negotiation.
Are the size of provider savings payments
con-tingent on considerations other than savings
achievement?
Almost every observed shared-savings model uses per-formance on access, patient experience, quality, and/or service utilization to determine the percentage of sav-ings the provider will receive. The measures most often tend to address preventive and chronic care services, and for ACO-like entities, acute care services.
Gates and ladders. In some models, perfor-mance measures serve to define a minimum qualifica-tion or “gate.” If the provider meets the minimum per-formance requirement, it is entitled to a fixed percent-age of savings. Other models are more complex. They define a gate, but also specify that the provider can increase its savings beyond that amount by performing better relative to a performance measurement set and moving up a “ladder.” In such instances, the percent-age of savings eligible for meeting the minimum stan-dards—that is, passing through the gate—is typically less than 50 percent.
The proposed Medicare Shared-Savings model may be the most complex example of this latter approach, with 65 measures spread over five perfor-mance domains, and providers expelled from the pro-gram for not meeting minimum performance standards
for one domain for two years. Each measure within a domain is worth a maximum of two points and a mini-mum of zero points, with points assigned based on per-formance relative to national Medicare fee-for-service and Medicare Advantage percentiles. An ACO would get a single score for the domain based on the percent-age of total points achieved. The averpercent-age of the five domain scores would be the overall score, which would determine the percentage of the shared savings an ACO receives.6
The Medicare Shared Savings Program design does not include, although it is common in other mod-els, the use of utilization measures. These measures typically assess the extent to which the provider is reducing preventable acute care service use including inpatient readmissions, potentially avoidable inpa-tient admissions, and potentially avoidable emergency department visits.
The use of utilization measures has been a topic of debate. The measures can be viewed as both quality measures but also as indicators of efficiency and cost savings. Some have argued that their inclusion represents a redundant incentive because, even without these measures, the provider will seek to achieve sav-ings through reduced need for and delivery of these services. Still, some payers insist on their inclusion because of the perceived imperative for the payers to reduce costs associated with utilization of these services.
In one model, quality measures were employed as the qualifying gate, while utilization measures deter-mined the percentage of savings earned above the gate. In other cases, quality, utilization, and other measures are not differentiated for purposes of evaluating perfor-mance and determining the percentage of distributed savings.
Overall, preventive care, chronic illness care (process measures and interim outcome measures), and utilization (efficiency) measures were all employed with approximately equal frequency in the studied models, while access and patient experience each appeared to be used about a third less often.
Benchmarks vs. improvement. Shared-savings models that use performance measures to determine
provider savings allocation tend to use three basic approaches. The first involves scoring provider performance relative to a benchmark. Examples include regional Healthcare Effectiveness Data and Information Set (HEDIS) percentiles and payer-defined percentiles, as in the CMS Shared Savings Program. As providers meet or exceed higher benchmarks for each measure or composite measure, they earn more points, which translate into a larger share of savings.
The second approach assesses the extent to which provider performance has improved compared with the prior year. Some models require the improve-ment to be statistically significant while others do not. The third approach is to consider both perfor-mance toward benchmarks and perforperfor-mance ment. One such example is to require annual improve-ment until such time that the provider reaches a high external benchmark, at which point the provider must only maintain performance at or above the benchmark year-over-year.
As with most every element of shared-savings model design, there are many variations in the applica-tion of the above approaches, including the following:
• the percentage of savings that is contingent on selected performance measures increases over a five-year phase-in period;
• either reporting measures or maintaining per-formance is required in the first year, while performance improvement is required in the years that follow;
• quality cannot be a consideration in a shared-savings distribution and the payer can operate a separate but parallel quality incentive pool; and
• quality scores can be combined into a compos-ite measure for assessment purposes to respond to the problem of small observation counts for small provider entities.
THE FUTURE FOR SHARED-SAVINGS
MODELS
Are shared-savings methodologies considered
long-term or transitional payment strategies?
Many provider and payer participants view shared-sav-ings payment methodologies as transitional, but with an undefined timeframe. Most providers and payers view their recent forays into shared savings as a learn-ing experience and do not presume to know when they will want or be ready to transition to a risk-based pay-ment arrangepay-ment with a combination of downside risk and greater upside risk. This approach stands in con-trast with the proposed CMS Shared Savings Program, which requires that ACOs transition to a reciprocal upside and downside shared-risk model after two years.A significant number of shared-savings partici-pants see the model as a long-term strategy, albeit with adjustments over time. At least one payer felt that pay-ment arrangepay-ments with downside provider risk would never be viable for smaller provider entities.
CRITICAL ISSUES IN SHARED-SAVINGS
DESIGN AND IMPLEMENTATION
This analysis has revealed a considerable amount of activity in the design and implementation of shared-savings payment models. It seems likely that additional outreach efforts would have yielded many more varied examples.
The current flurry of activity is sparking cre-ativity and the opportunity to try different approaches. This natural experimentation will facilitate learning, as not all efforts are likely to be equally effective. The trade-off for this experimentation will be the variety of models and performance measures that providers will face and the difficulty for providers trying to respond to disparate incentives.
It is difficult to know what will be the determining success factors for shared-savings payment models, but there are a few critical issues to address and resolve.
Determining if Savings Have Been
Achieved
Very few interviewees identified this issue as central, but it appears it will be an increasing source of con-flict. For those who spoke about it, the topic was the basis for extensive research, analysis, and negotiation. Unless shared-savings programs are implemented only with the very largest of provider organizations—and this scenario seems unlikely—payers and providers must resolve the tension between statistical certainty that savings have been realized and providing a mean-ingful and attainable incentive for providers to generate savings.
Ensuring Providers Succeed
Payment reform provides an incentive for transforma-tion of care delivery, but it does not ensure it. While most interviewed providers recognized this, the pay-ers did not always convey the same undpay-erstanding. In order to succeed, providers will need certain tools.
Timely, trended performance data with targets and benchmarks, and the ability to manipulate data.
Most payers are making some data available, but pro-viders need more information. In addition, the provided data are neither consistent nor integrated across payers, except in cases where payers are sending non-Medicare claims files to providers who do their own claims aggregation. Medicare is particularly challenged to provide this support.
Knowledge and implementation of systems and processes to deliver better care more efficiently. While some interviewed payers expressed an assumption that large organizations would be able to “figure it out,” there are reasons to doubt that providers will always know how to fundamentally transform their businesses. The largest provider organizations have invested heav-ily in consulting services, process redesign, and infra-structure development, but not all provider organiza-tions have the capacity to do so. Smaller provider orga-nizations and those in poor financial health may have great difficulty responding to the incentive presented by the opportunity to share savings.7
Aligning Measurement
While some degree of variation across payers may be of value in the near term, competing sets of per-formance measures in shared-savings methodologies could eventually harm the effectiveness of the payment models, since providers will find it difficult to focus. There may be opportunities for regional coalitions to identify a common framework with which nonfederal payers might align.
Refining the Shared-Savings Model
National expectations are high that payment and deliv-ery system reform, simultaneously being advanced by both public and private sector payers, will finally slow the inexorable march of health care cost growth. The scope and complexity of the challenge make it unlikely that the great expectations of today will be immediately realized tomorrow. It will be necessary to learn within and across payer and provider organizations from ini-tial successes and failures and to maintain a resolve to persistently refine the payment model to maximize effectiveness.
HOW THIS STUDY WAS CONDUCTED
This issue brief is one of several projects funded by The Commonwealth Fund to document alternative pay-ment models. Most closely related is a project being conducted in parallel by Catalyst for Payment Reform
to identify and document ACO shared-risk programs in the public and private sectors. The two project teams have collaborated in their respective work to ensure as comprehensive a list of shared-savings and shared-risk models as possible.
Bailit Health Purchasing conducted 32 tele-phone interviews with payer and provider organiza-tions and state agency agencies that indicated they were involved in 27 independent past, current, and planned shared-savings payment arrangements. Interviews were performed using a structured instru-ment. In addition, Bailit considered the Notice of Proposed Rule-Making for the Medicare Shared Savings Program, released on March 31, 2011, by the Centers for Medicare and Medicaid Services (CMS), as an additional shared-savings model for comparative analytical purposes.
The assessed shared-savings programs were primarily applied in primary care practice medical home programs and in ACO-like payment arrange-ments involving a more broadly defined provider organization such as a multispecialty group prac-tice, integrated delivery system, physician–hospital
organization, or independent practice association. While the medical home shared-savings programs also involved the payment of supplemental payments (typi-cally per member per month), the ACO-like shared-savings programs did not.
Approximately one-third of the arrangements were formed through medical home or medical home-like programs. Because the medical home and ACO-like shared-savings models did not differ considerably in construction beyond medical home programs provid-ing supplemental per member per month payments, the findings are reported in an integrated fashion.
With the notable exception of the Medicare Physician Group Practice demonstration and experi-ence in California, most of the case examples have been of relatively short duration.8 Approximately
two-thirds of the arrangements had 2010 or 2011 start dates. In addition, only the Physician Group Practice demon-stration had been formally evaluated for effectiveness.9
Finally, it is worth noting that not all self-described shared-savings models meet the defini-tion provided above. In one instance an interviewee revealed that an insurer operated a predefined bonus pool that distributed bonus payments based on pro-vider success in reducing costs. In another instance, the extent to which a provider generated savings influ-enced the degree to which the provider’s fees would be increased in the following year.
notes
1 D. McCarthy, R. Nuzum, S. Mika, J. Wrenn, and
M. Wakefield, The North Dakota Experience: Achieving High-Performance Health Care Through Rural Innovation and Cooperation (New York: The Commonwealth Fund, May 2008); and M. Bailit,
Payment Rate Brief (Washington, D.C.: Patient-Centered Medical Home Initiative, March 2011).
2 By excluding acute-care services due to accidents
over which the provider may have little perceived influence, at least one initiative believed it could reduce the amount of random variation in medical expenses. It is worth noting that Medicaid payers view accidents as potentially preventable, since they may be attributed to misuse of alcohol or other substances.
3 The circumstances are as follows: 1) all ACO
par-ticipants are physicians or physician groups; 2) 75 percent or more of the ACO’s assigned beneficiaries reside in counties outside a metropolitan statistical area; 3) 50 percent or more of the ACO’s assigned beneficiaries were assigned on the basis of services received from Method II Critical Access Hospitals; and 4) at least 50 percent of the ACO’s assigned beneficiaries had at least one encounter with a par-ticipating rural health clinic or federally qualified health center.
4 Centers for Medicare and Medicaid Services,
What Providers Need to Know: Accountable Care Organizations (Washington, D.C.: U.S. Department of Health and Human Services, April 2011), http:// www.cms.gov/MLNProducts/downloads/ACO_
Providers_Factsheet_ICN903693.pdf.
5 In arrangements where the payer has provided
pro-spective payments, as is common in medical home models, those payments are typically netted out of any savings.
6 M. A. Zezza, Proposed Rules for Accountable Care
Organizations Participating in the Medicare Shared Savings Program: What Do They Say? (New York: The Commonwealth Fund, April 2011).
7 Research suggests that pay-for-performance has
proven less effective with hospitals in poor financial health than for those in a strong financial condition. See R. M. Werner, J. T. Kolstad, E. A. Stuart et al., “The Effect of Pay-for-Performance in Hospitals: Lessons for Quality Improvement,” Health Affairs,
April 2011 30(4):690–98.
8 This demonstration was a model for the Medicare
Shared Savings Program. Its design differed from the proposed draft Shared Savings Program in several ways. A few examples include 1) the dem-onstration’s focus on very large practice organiza-tions, 2) the demonstration’s exclusive use of shared savings (and not shared risk), and 3) the use of an external control group to assess savings achieve-ment as opposed to calculating expected spend-ing based on the previous three years of historical expenditures for the same assigned patients.
9 The evaluation concluded, “The improvement in
the quality measure processes and reporting in the first two years of the demonstration suggest that access has been improved while providing high quality care. The effect of the demonstration on promoting expenditure savings is less certain.” See K. Sebelius, Report to Congress: Physician Group Practice Demonstration Evaluation Report
(Washington, D.C.: U.S. Department of Health and Human Services, 2009), http://www.cms.gov/ DemoProjectsEvalRpts/downloads/PGP_RTC_Sept. pdf.
Appendix. Interviewed Organizations
Organization Organizational Type
Advantra Total Care (KS) Provider
AdvocateCare (IL) Provider
Anne Arundel Health Systems (MD) Provider
Anthem Blue Cross (CA) Payer
Baptist Health System (TX) Provider
Billings Clinic (MT) Provider
Blue Cross Blue Shield of Illinois Payer
Blue Cross Blue Shield of Minnesota* Payer
Blue Cross Blue Shield of Tennessee Payer
Blue Shield of California Payer
Capital Blue Cross (PA) Payer
CareFirst (MD) Payer
Centers for Medicare and Medicaid Services (Medicare Physician Group
Practice Demonstration) Payer
Centers for Medicare and Medicaid Services (MMA 646 Medicare Health Care
Quality Demonstration programs in Indiana and North Carolina) Payer
Everett Clinic (WA) Provider
Fairview Health System (MN) Provider
Geisinger Health System (PA) Provider
Harvard Pilgrim (MA) Payer
Health Partners (MN) Provider
Independence Blue Cross (PA) Payer
Maryland Health Care Commission State
Massachusetts Executive Office of Health and Human Services State
Medica (MN) Payer
Northwest Physicians Network (WA) Provider
Norton Healthcare (KY) Provider
Pennsylvania Governor’s Office of Health Care Reform State
Prometheus Payment Payment organization
Regence BlueShield of Washington Payer
Tucson Medical Center (AZ) Provider
UW Medicine Neighborhood Clinics (WA) Provider
Washington Health Care Authority State
WellStar Health System (GA) Provider
Note: In a few instances a consultant to a state was interviewed in lieu of state personnel. * Interview performed by Booz Allen and results shared with Bailit Health Purchasing, LLC.
aBout the authors
Michael Bailit, M.B.A., is president of Bailit Health Purchasing, LLC. For the past 15 years, Mr. Bailit has
worked extensively with public agencies, purchaser coalitions, and employers to advance the effectiveness of their health care purchasing activities. He previously served as assistant commissioner for the Massachusetts Division of Medical Assistance and as a benefits manager for Digital Equipment Corporation. He also has expe-rience working in the health insurance industry. Mr. Bailit received a master of business administration degree from the Kellogg Graduate School of Management at Northwestern University.
Christine Hughes, M.P.H., has been a senior consultant with Bailit Health Purchasing for more than 10 years.
Ms. Hughes’ work at Bailit Health includes research on best practices regarding: payment reform, patient- centered medical homes, pay-for-performance, and value-based insurance design. She previously served as Deputy Director for the Medicaid Managed Care Program at the Massachusetts Division of Medical Assistance. She also has experience in network contracting with a large integrated delivery system (Partners Community Health Care) and a staff model HMO (Health Care Plan). Ms. Hughes received a master of public health degree from Boston University School of Public Health.
acKnowledgMents
The authors would like to thank Stu Guterman and Anne-Marie Audet for their advice and feedback, and Suzanne Delbanco and Catherine Eikel Major for collaborating while conducting the parallel studies.
Issue Brief: How to Improve the Medicare
Accountable Care Organization (ACO) Program
JUNE 2014
Authors: Mark McClellan, Director, Health Care Innovation and Value Initiative and Senior Fellow; Ross White, Project Manager; Larry Kocot, Visiting Fellow; The Engelberg Center for Health Care Reform at Brookings.
The authors would like to acknowledge the following individuals for their contributions and editorial support: Alice M. Rivlin, Director, Engelberg Center for Health Care Reform, Senior Fellow, Economic Studies; Farzad Mostashari, Visiting Fellow; and Christine Dang-Vu, Project Manager.
Introduction
Recent data suggest that Accountable Care Organizations (ACOs) are improving important aspects of care and some are achieving early cost savings, but there is a long way to go. Not all ACOs will be successful at meeting the quality and cost aims of accountable care. The private sector has to date allowed more flexibility in terms of varying risk arrangements—there are now over 250 accountable care arrangements with private payers in all parts of the country—with notable success in some cases, particularly in ACOs that have been able to move farther away from fee-for-service payments. Future growth of the Medicare ACO program will depend on providers having the incentives to become an ACO and the flexibility to assume different levels of risk, ranging from exclusively upside arrangements to partial or fully capitated payment models.
Given that the first three year cycle of Medicare ACOs ends in 2015 and more providers will be entering accountable care in the coming years, the Centers for Medicare and Medicaid Services (CMS) has indicated that they intend to release a Notice of Proposed Rulemaking (NPRM) affecting the Medicare ACO Program.
In anticipation of these coming changes, the Engelberg Center for Health Care Reform has identified a number of critical issues that warrant further discussion and considerations for ensuring the continued success of ACOs across the country. To support that discussion, we also present some potential alternatives to current Medicare policies that could address these concerns. These findings build on the
experiences of the Engelberg Center’s ACO Learning Network members and other stakeholders
implementing accountable care across the country. In some cases, the alternatives might have short-term costs, but could also improve the predictability and feasibility of Medicare ACOs, potentially leading to bigger impacts on improving care and reducing costs over time. In other cases, the alternatives could lead to more savings even in the short term. In every case, thoughtful discussion and debate about these issues will help lead to a more effective Medicare ACO program.
Accountable Care Organizations (ACOs) represent an increasingly widespread approach to address inefficiencies, lack of coordination, poor quality care, and increasing costs in the US health care system. While there is considerable diversity in organizational structure and payment models among ACOs, they all have the common goal of controlling health care costs while improving the quality of care they deliver. Ultimately, an ACO aims to move toward a payment and delivery system that provides high value person-focused care.
The number of Medicare ACOs continues to increase since the first round of participants was announced in 2012. The Medicare Shared Savings Program (MSSP) is an example of a “shared savings” model, in which participating ACOs are eligible to earn an additional payment on top of existing FFS payments if they reduce spending below a benchmark and meet quality standards. In almost all cases, these ACOs are not subject to penalties (“downside risk”) if they spend more than projected—only a handful of MSSPs have assumed downside risk to date. This one-sided risk model is a first step toward provider accountability to encourage work across the care continuum to reduce overall costs. There are currently 338 MSSP participants. ACOs with more experience and infrastructure to support care reforms may take on “two-sided” risk, including partial capitation, to provide more incentive and flexibility to redirect resources to high-value services. This includes the 23 participants in the Medicare Pioneer Program, as well as a growing number of ACOs working with private plans.
First year financial results are now available for both the MSSP and Pioneer ACOs. Of the 114 MSSP ACOs that joined the program in 2012, 54 were able to keep costs below their budget benchmark, but only 29 were able to hold down costs enough to qualify for shared savings. These successful ACOs received $126 million in savings, while the CMS trust fund realized savings of $128 million, around 1 percent of costs. The other 60 MSSP ACOs experienced spending above their set benchmark, two of which had losses because they chose to assume two-sided risk upon entering the program. Meanwhile, the Pioneer program generated $147 million in total savings, with approximately $76 million in savings returned to
ACOs and $69 million returned to Medicare, around 2% of costs. Of the original 32 Pioneer ACOs, 12 qualified for shared savings, one shared in losses, and 19 did not share in savings or losses. Almost all MSSP participants and Pioneer ACOs successfully reported on quality metrics, a majority of which performed better than comparable organizations where data was available.
These results suggest that ACOs are improving important aspects of care and some are achieving early cost savings, but there is a long way to go. Not all ACOs will be successful at meeting the quality and cost aims of accountable care. The private sector has to date allowed more flexibility in terms of varying risk arrangements—there are now over 250 accountable care arrangements with private payers in all parts of the country—with notable success in some cases, particularly in ACOs that have been able to move farther away from fee-for-service payments. Future growth of the Medicare ACO program will depend on providers having the incentives to become an ACO and the flexibility to assume different levels of risk, ranging from exclusively upside arrangements to partial or fully capitated payment models.
Given that the first three year cycle of Medicare ACOs ends in 2015 and more providers will be entering accountable care in the coming years , the Centers for Medicare and Medicaid Services (CMS) has indicated that they intend to release a Notice of Proposed Rulemaking (NPRM) affecting the Medicare ACO program. In anticipation of these coming changes, the Engelberg Center for Health Care Reform has identified a number of critical issues that warrant further discussion and considerations for ensuring the continued success of ACOs across the country. To support that discussion, we also present some potential alternatives to current Medicare policies that could address these concerns. These findings build on the experiences of ACO Learning Network members and other stakeholders implementing accountable care across the country. In some cases, the alternatives might have short-term costs, but could also improve the predictability and feasibility of Medicare ACOs, potentially leading to bigger impacts on improving care and reducing costs over time. In other cases, the alternatives could lead to more savings even in the short term. In every case,
