Next week is the deadline to notify Medicare if your practice intends to participate in a new payment model aimed at helping practices, particularly smaller ones, meet the Quality Payment Program requirements under MACRA.
The Centers for Medicare & Medicaid Services (CMS) created a new Advanced Alternative Payment Model in December called the Medicare Accountable Care Organization Track 1+. This model limits some of the downside risks that practices face in Track 2 and Track 3 under Medicare’s Shared Savings program as CMS tries to encourage more practices to participate in risk-sharing agreements.
Accountable Care Organizations (ACOs) in Track 1+ will be eligible for shared savings up to 50 percent, based on quality performance. There is a fixed 30 percent loss sharing rate. The maximum level of downside risk depends on the composition of the participating ACOs. Track 1+ is largely based on Track 1 and incorporates aspects of Track 3, such as prospective beneficiary assignment and a three-day rule waiver for skilled nursing facilities. Track 1+ qualifies as an Advanced Alternative Payment Model (AAPM) under Medicare’s Quality Payment Program beginning in 2018. Qualifying AAPM participants are eligible to receive a 5 percent bonus payment.
Track 1+ is open to current and renewing ACO Track 1 participants as well as new participants. Those already participating in Track 2 or Track 3 cannot apply.
If your practice would like to participate in Track 1+, you must first submit to Medicare a notice of intent to apply (NOIA). The deadline for filing a NOIA is noon ET on May 31. The Centers for Medicare and Medicaid Services (CMS) has published a user guide to help physicians through the NOIA process. After submitting an NOIA, physicians must complete the Track 1+ application July 1-31. Sample 2018 applications will be made available in June.
– Erin Solis, Regulatory Compliance Strategist for the American Academy of Family Physicians
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