Health System Reform Insight - Nov. 17, 2011

The Centers for Medicare & Medicaid Services (CMS) has announced several key deadlines for prospective accountable care organizations (ACO) interested in applying for the Medicare Shared Savings Program and the Advance Payment Model. This announcement follows publication of a final rule on the ACO program, which included numerous AMA recommendations. Several significant improvements that CMS made in the final rule were detailed in the last issue of Health System Reform Insight.

2012 deadlines for the Medicare Shared Savings Program
Prospective Medicare ACOs interested in applying for the Shared Savings Program in 2012 can choose between two start dates: April 1 and July 1. The first step in the process will be to complete a non-binding notice of intent (NOI) by the dates specified below.

An organization can submit an NOI but later decide not to apply to become a Medicare ACO.

Key dates:

	Start date: April 1, 2012	Start date: July 1, 2012
Shared Savings Program applications posted on CMS’s website	Fall 2011	Fall 2011
Deadline for NOI forms	Jan. 6	Feb. 17
Deadline for CMS user ID forms	Jan. 12	Feb. 23
2012 ACO applications accepted	Dec. 1–Jan. 20	March 1–30
2012 Advance Payment Model applications accepted	Jan. 1–Feb. 1	March 1–30
CMS delivers application approval or denial decision	March 16	May 31
Reconsideration review deadline*	March 23	June 15

*If an applicant does not receive approval and applies for reconsideration, the applicant must receive a favorable reconsideration determination by this date in order to qualify for the start date specified on the application.

Once CMS processes the NOI, the ACO will receive an acknowledgement letter via email that contains the ACO’s user ID and detailed instructions on how to complete the CMS user ID application, which must be sent via tracked mail (e.g., UPS, FedEx) by a specific date. The CMS user ID will allow the applicant to complete the ACO application package electronically through CMS’s website.

Send completed CMS user ID applications to:

Centers for Medicare & Medicaid Services
Attention: Gregory Buglio
Mail Stop: C4-18-13
7500 Security Boulevard
Baltimore, MD 21244

The ACO application package can be completed either electronically by following the instructions contained in the CMS user ID notice or through paper submission (which must be sent via tracked mail and include an original signature).

The application must include the following documents:

• Application
• Electronic funds transfer authorization (CMS Form 588, Appendix A)
• Participant list template (Appendix B)
• CMS data use agreement (Appendix C)

Send completed ACO applications to:

Centers for Medicare & Medicaid Services
Attn: SSP ACO Applications
Mail Stop: C5-15-12
7500 Security Blvd.
Desk Location: C4-07-01
Baltimore, MD 21244

2012 deadlines for the Advance Payment Model
The Advance Payment Model is offered by the Center for Medicare and Medicaid Innovation within CMS. Participating ACOs will receive three types of payments: an upfront fixed payment, an upfront variable payment and a monthly payment of varying amount depending on the ACO’s size. CMS will recoup advance payments through the ACO’s earned shared savings.

Prospective ACOs interested in also applying for the Advance Payment Model must submit a separate application in addition to their Shared Savings Program application.

Only two types of ACOs are eligible for the Advance Payment Model:

• ACOs that do not include any inpatient facilities and have less than $50 million in total annual revenue.
• ACOs in which the only inpatient facilities are critical access hospitals or Medicare low-volume rural hospitals and have less than $80 million in total annual revenue.

In addition, the Advance Payment Model is being offered only to ACOs with start dates in April or July 2012. Advance Payment Model applications will be accepted during January for ACOs starting in April and during March for ACOs starting in July.

Advance Payment Model applications will be posted on CMS’s website later this year.

Questions about an application?

Contact CMS for additional information. Email SSPACO_Applications@cms.hhs.gov with questions about the Medicare Shared Savings Program application process, or email advpayaco@cms.hhs.gov with questions about the Advance Payment Model application process.

Nov. 21
A free AMA webinar at 7 p.m. Eastern time, featuring AMA President-elect Jeremy Lazarus, MD, and national expert Harold Miller, will outline the significant improvements in the Medicare ACO program final rule and discuss the application process. Register today.

Nov. 23
The Joint Select Committee on Deficit Reduction is scheduled to approve a proposal to reduce federal spending by at least $1.2 trillion. Tell Congress that repeal of Medicare's flawed sustainable growth rate (SGR) formula must be part of the committee's proposal.

Dec. 31
Physicians who wish to change their Medicare participation status must do so by the end of the year. The AMA's newly updated Medicare Participation Kit explains the Medicare participation options to help physicians assess which one might be best for their practices.

Medicare physician payment reform action kit

AMA comments on Affordable Care Act implementation regulations

AMA physician manual on ACOs