Anyone thinking about applying for participation in the Medicare Shared Savings Program ( MSSP ) for calendar year 2014 needs to act soon. View the PYA white paper, Medicare ACO Roadmap, and note the following critical dates:
- May 30, 2013–Completed Notice of Intent ( NOI ) is due. NOI must be submitted to the Centers for Medicare & Medicaid Services ( CMS ) by this date. If an organization misses this deadline, it cannot apply for participation in the MSSP until the 2015 cycle.
- June 10, 2013—CMS User ID form is due. After submission of the NOI, an applicant will receive an identification number from CMS. Using this number, the applicant must submit a completed CMS User ID form. Again, missing this deadline means having to wait another year to apply.
- July 31, 2013—Full MSSP application is due.
If a provider (or group of providers) is unsure about participating in the 2014 MSSP cycle, it should be aware of the following:
- Submitting an NOI or a CMS User ID form imposes no obligation on the filing entity to actually complete and submit an application by the July 31 deadline.
- CMS does not charge any fee to file these forms. Completing the NOI and the CMS User ID form merely holds a place in line should the applicant decide to take the next step.
- Potential applicants concerned about their inability to form a separate legal entity (and obtain a federal tax ID number) to file the NOI need not let this be a hindrance. Instead, providers can file the NOI and CMS User ID form under an existing federal tax ID number, and then reassign the MSSP once the new entity is formed.
Even if a group of providers is not ready to jump on board with the MSSP this year, there are definite advantages to getting the NOI and CMS User ID form on file now:
- The assigned CMS User ID can be used to submit the application next year.
- Completing these filings may constitute a clear declaration of intent to form an accountable care organization ( ACO ) for purposes of the MSSP pre-participation waiver. This waiver provides applicants latitude with respect to planning, sharing of information, and organizational structure that might otherwise be deemed impermissible by the fraud and abuse laws and the prohibitions on gainsharing and certain patient inducements. Interested providers should consult their legal counsel for guidance on these waivers.
Preserve your ability to participate in the 2014 MSSP today. PYA can support your organization in the journey to participate in the MSSP by completing and filing the NOI and CMS User ID form. We also offer the full range of services to complete the myriad of tasks associated with the MSSP application. For more information, please contact the experts listed below at (800) 270-9629.
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