While You Are Waiting: Getting Ready to Apply for the MSSP

About one-third of all hospitals and clinicians now participate in the Medicare Shared Savings Program (MSSP).  For those considering participation, the Centers for Medicare & Medicaid Services (CMS) offers a once-a-year opportunity for accountable care organizations (ACOs) to join the program.

In prior years, an applicant was required to submit a Notice of Intent to Apply by the end of May to begin the process of joining the MSSP at the beginning of the next calendar year.

May 2018 has come and gone, and CMS has yet to release the 2019 MSSP application schedule.  The agency is offering no explanation for the delay, and no hint about when the schedule may be released.

If your organization is considering forming an ACO, joining an existing ACO, or renewing an existing MSSP ACO for another term, there’s some important work you can be doing while we wait for more direction on the 2019 application cycle from CMS:

(1)  Study up on the program.  The concept behind the MSSP is simple enough:  help reduce Medicare’s total cost of care for a defined group of beneficiaries, and CMS will reward you with a cut of the savings.  In execution, however, the program is more complicated.  There are rules regarding attribution, benchmarks, participants, minimum savings rates, and waivers, to name a few.

PYA’s MSSP ACO Roadmap offers concise, easy-to-follow instructions to navigate the rules and regulations for participation in the MSSP.  The Roadmap, a key resource for organizations considering MSSP participation, covers five areas: (1) the case for MSSP participation, (2) ACO formation and MSSP application, (3) operations, (4) shared savings payments, and (5) private payer programs.  We’ll be updating the 2018 version of the Roadmap as soon as CMS announces the application process for 2019.

(2)  Secure commitments.  In our experience, the most challenging part of the MSSP application process is getting the individual participant agreements in order.  Each Taxpayer Identification Number (TIN) that will be part of your ACO must sign a participant agreement that complies with specific MSSP requirements, and certain information regarding each TIN must be submitted with the application.  In discussions with potential participants, be sure to set the expectation that timely completion and submission of all documents is an absolute necessity.

(3)  Discuss organizational structure and governance.  Some of the most complicated rules and regulations referenced above concern an ACO’s corporate form and governance.  In addition to checking the right boxes, your ACO should be structured to promote physician engagement, one of the most important ingredients for success.    

(4)  Build vs. Buy.  Many companies now offer turnkey MSSP solutions, handling ACO formation and the application process and then providing ongoing management, technology solutions, and their own formulas for success.  Typically, these companies charge a start-up fee and ongoing per-beneficiary-per-month fees and take a cut of any shared savings.

By contrast, PYA helps organizations plotting their own course based on their specific circumstances, customizing the resource planning to ensure organizations pay only for what they need to be successful.  Our approach isn’t “one size fits all.”  When it comes to MSSP participation, every provider’s circumstances, environment, and culture is unique.  PYA offers unique solutions, developed through our team’s years of experience assisting MSSP participants, to our MSSP clients.

We’ll keep you posted on details relating to the 2019 application process.  In the meantime, we’re happy to discuss your MSSP questions.  Contact Martie Ross (mross@pyapc.com) or Aaron Elias (aelias@pyapc.com) for more information, or to talk about your unique MSSP strategies.


Martie Ross

Martie Ross

Principal

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