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Track 1: Upside gainsharing for two years with two-sided risk on the third year. ACOs that opt for this track will get 50% of the upside savings that is capped at 10% of the benchmark. Track 2: Upside and downside risk sharing for all three years. ACOs in this track get 60% of the upside savings, while the downside is capped at 5%, 7.5% and 10% for years 1, 2 and 3, respectively. Payment is capped at 7.5% of the benchmark. CMS proposes that the upside risk payment only occur when two things happen 1) a savings threshold ("minimum savings rate") is exceeded. ACOs in Track 2 will need to get above a 2% savings versus a calculated benchmark. Track 1 ACOs, especially those that are smaller or in rural or underserved areas, have both good and bad news. The good news is that their benchmark can be as low as 0% (especially if they are in underserved or rural areas) but the bad news is that may need to achieve a higher level of savings over that benchmark. The DMCB read that level may go, depending on size, as high as 3.9% The smaller population, the greater the statistical variation that can plague the measurement of savings; 3.9% over the benchmarks increases the statistical likelihood that the observed savings are real. 2) a composite measure of more than 60 clinical quality performance measures is met or exceeed. Exceeding them can earn extra shared savings: up to 2.5% for Track 1 above (adding up to a max of 52.5%) and 5% for Track 2 (adding up to a max of 65%). Achieving these measures can also blunt the downside losses. It appears that CMS also proposes to hedge against future downside adverse risk development by holding back 25% of any bonus. Next stop: figure out how the benchmarks are determined and what will go into the risk adjustment. If the DMCB has any of this wrong, please comment! |
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