Accountable Care, health innovation challenges, health insurance reform, MSSP, Triple Aim

The Next Generation ACO: Accelerating the Transformation from Volume to Value

In January 2015, then Secretary of Health and Human Services (HHS), Sylvia Burwell outlined ‘Federal policy‘ and for the first time put a measurable stake in the ground to scale the pivot from fee-for-service to value based healthcare with concrete milestones and an associated timeline. The policy outlined seemingly scalable goals via linking 30% of traditional fee-for-service Medicare payments to quality or value through ‘alternative payment models‘ (APMs) including Patient Centered Medical Homes (PCMHs), ACOs or ‘bundled payment arrangements‘ (BPHCI) year end 2016, scaled up to 50% of payments year end 2018. For details see: ‘HHS Sets Specific Targets and Timelines for Alternative Payment Models and Value-Based Payment‘.

Now fast forward to 2017. First introduced in 2016 we’re approaching the start date of a ‘new and improved‘ ACO tagged the ‘next generation ACO model‘ now embracing an ‘all in population based payment‘ (AIPBP) option that ZERO’s out fee-for-service payments.

Between ACO operating results, significant provider community feedback via several Notice of Proposed Regulations‘ (NPRMs) and what some may say is simple commonsense, this latest iteration of the Next Generation ACO model is looking more and more like their predecessor risk bearing operators in the 80s and 90s.

As CMS notes:

Building upon experience from the Pioneer ACO Model and the Medicare Shared Savings Program (Shared Savings Program), the Next Generation ACO Model offers a new opportunity in accountable care—one that sets predictable financial targets, enables providers and beneficiaries greater opportunities to coordinate care, and aims to attain the highest quality standards of care.

The Next Generation ACO Model is an initiative for ACOs that are experienced in coordinating care for populations of patients. It will allow these provider groups to assume higher levels of financial risk and reward than are available under the current Pioneer Model and Shared Savings Program (MSSP). The goal of the Model is to test whether strong financial incentives for ACOs, coupled with tools to support better patient engagement and care management, can improve health outcomes and lower expenditures for Original Medicare fee-for-service (FFS) beneficiaries.

The Bottom Line

We (i.e., ACO industry operators, associated management companies’ including venture financiers, CMS and supplier stakeholders) are tweaking the ACO formula via a range of models that materially engage the provider AND payor communities as co-creators of a sustainable healthcare ecosystem embracing value and outcomes as the ‘dependent variable’.

With the uncertainty surrounding the future of the ACA and it’s likely ‘Trumpcare’ or ‘RyanCare’ replacement options, some argue ACOs are in an unspoken ‘safe harbor’ of sorts. Yet, much detail remains to be added before that picture is functionally revealed. Here at ACO Watch we’re proceeding on the assumption that ACOs or the accountable care industry collectively, are not likely to disappear anytime soon. So we’re posting some resources below:

For a deep dive into the AIPBP option CMS is hosting an Open Door Forum: Next Generation ACO Model – Overview of Population-Based Payments on Tuesday, April 11, 2017 from 4:00PM – 5:00 P.M. EDT.

For those pondering their 2018 ACO participation options, CMS‘s Center for Medicare and Medicaid Innovation (CMMI) issued an RFA (request for applications) and activated the application portal here.  

Finally to complete the picture CMS is hosting a series of open forums to provide an overview into the Next Generation ACO model offering information on the required letter of intent and on-boarding process in general on these dates as follows:

  • March 14 from 4 – 5 pm ET — Application Overview and Participating Provider Lists
  • March 28 from 3 – 4 pm ET — Benefit Enhancements Overview
  • April 11 from 4 – 5 pm ET — Overview of Population-Based Payments & All-Inclusive Population-Based Payments;and
  • April 15 — Deep Dive: Completing Your Next Generation ACO Model Participant List

For the complete list of available CMS ACO resources, click here.

And finally for those who desire an overview of the ACO theater, check out the dated but informative: ‘Accountable Care Organization (ACO) 101: A Brief Course by Neil Kirschner, Ph.D. Director, Regulatory and Insurer Affairs, American College of Physicians (ACP).




Accountable Care, ACO, Affordable Care Act

The NextGen ACO: Another Round Opens

by Gregg A. Masters, MPH

The Centers for Medicare and Medicaid Innovation has announced the results of its ‘continuous learning‘ commitment model wherein ‘field reports‘ including provider comments and open door inputs are materially incorporated into tweaks of the Medicare Shared Savings Program (MSSP) as risk is progressively adopted by participating ACOs. This ‘new round’ iteration no doubt includes ‘lessons learned‘ from the Pioneer ACO Program including the many ‘exits’ and risk downgrades opted to date.

In summary, this round is:

‘ that sets predictable financial targets, enables providers and beneficiaries greater opportunities to coordinate care, and aims to attain the highest quality standards of care.’



For complete information, see: ‘Next Generation ACO Model | Center for Medicare & Medicaid Innovation‘.




Wal*Mart: RFI ‘Overwritten and Incorrect’

By Gregg A. Masters, MPH

Whoa! Not 24 hours after the Request for Information (RFI) issued by WalMart Health and Wellness directed to it’s ‘strategic partner’ downline hit the street, I mean was leaked to the press, WalMart’s senior management felt compelled to promptly backdown from it’s rational, comprehensive, timely and sensible approach to make a meaningful dent into the US Healthcare, I mean, ‘Sickcare’ quagmire, by issuing the following terse statement:

Walmart Statement in Response to Health & Wellness Request for Information

“The RFI statement of intent is overwritten and incorrect. We are not building a national, integrated, low-cost primary care health care platform.”
– John Agwunobi M.D., Senior Vice President & President of Walmart U.S. Health & Wellness

Yikes! What’s behind this ‘whiplash’ effect?

It’s not news that WalMart has a mixed history with respect to the way they manage or evade (depending on your point of view) offering health benefits as an incentive to their less than full time staff. Yet, WalMart is the ‘400 pound gorilla’ as Chukwuma I. Onyeije, M.D., aka @chukwumaonyeije opined in a Google+ thread to a pool of health care social media peeps on Wednesday.

Regardless of the creative health benefits offer or ‘avoidance strategy’ for their part time staff, WalMart who’s gross sales account for approximately .5% of total US GDP, is a behemoth and perhaps second only to the Federal Government, the single largest ‘wholesale buyer’ of health benefits in the US.

So when they retained Price Waterhouse Coopers to consult on the compiling and distribution of an RFI to the tighly held ‘strategic partner’ network, they clearly intended to step into the population management fray of the payor/provider conundrum. You know, your costs are my revenues…

I’ve suspected all along, that while many on the provider side whine about CMS, the PPACA and now final rule to implement ACOs, many forward thinking peeps, mostly the Wall Street crowd who smell profits in those emerging re-engineered rules around population health management are stepping foward, perhaps aided and abetted by the so called ‘2nd in position skin in the game’ employer community.

We’ll watch and report with interest how this drama and retraction plays out.

See recent article released today by NPR, ‘Wal-Mart’s Clarification on Health Care Leaves Room For Big Moves‘.


#occupyhealthcare: Hype or Hope?

By Gregg A. Masters, MPH

Sunday, November 6th 2011 may mark a tipping point in the weak-tied and ‘talk is cheap‘ happy talk often characteristic of episodic and even planned healthcare social media conversations. While a dedicated and passionate community mostly focused on learning, defining, sharing best practices and what constitutes the ‘meaningful use’ of this emerging communications and community building media, there is no consensus of what the social media value proposition is or should be in healthcare. Is it marketing, customer service, stakeholder data mining, more effective messaging and engagement; or is it about transformation of a house of cards, on the verge of implosion dysfunctional sick care enterprise?

In my view and as I tweeted on the front end:

‘If you’re not about the business of transformation, you are taking up too much bandwidth.’

Editor’s Note: If social media is to create ‘real value’, then it must be able to tame the beast aka ‘the healthcare borg’ or ‘conundrum‘ that passes for the American healthcare system today.

Context for the Tweetchat could be found in the blog post titled: The Fatal Flaw in American Healthcarewhich among other indicia include the spiraling cost of health insurance and ‘diminishing returns’ nature of the benefits offered, the unsustainability of the premium trend trajectory even with the massive cost shifting underlying the health plan industry’s evolving underwriting gimmickry, the number of uninsured, growing pools or ‘under-insured’, on and on.

So on a day when the tribe would usually assemble for a #hcsm conversation, the room was full of healthtweeps who wanted to register their concern for, interest in, and intention to be part of a process that generally would pivot the conversation and perhaps action in a direction to remedy some if not all of these admitted ‘flaws’.

What followed was a barrage of Tweets, but those stats are summarized as follows:

Number of Tweets: 1935
Average Tweets per Hour: 74.42
Number of Participants: 317
Average Tweets per Participant: 6.1

The actual transcript from the TweetChat can be accessed here.

So what’s this got to do with ACO, accountable care and health reform? I float a point of view in my next post.


Dr. Don Berwick on ACO’s: From Volume to Value

By Donald Berwick, MD

Editors Note: Thanks to a tweet today via @AxSys_Health

CMS Administrator Don Berwick, M.D., explains ACO’s in plain language.

Hi, I’m Don Berwick, CMS administrator. Today’s a kind of red letter day, October 20th 2011. That’s the day in which we launch the Accountable Care Organization final rule and I just want to spend a minute describing this to you a bit.

This is one of the most exciting and important elements the Affordable Care Act. When we think about the goal of transforming American medicine into the kind of care that we all want for ourselves and our loved ones. American medicine is fragmented right now.

You get lost between the slats because we built the system that way, we pay for it that way, we train for it that way and institutions manage themselves separately. That’s not what patients need. That’s not what you want and I want. We want continuity and seamlessness and most of all we want to stay home and healthy instead of being in hospital beds or sick if we can avoid it.

We are trying now through all the policies in the Affordable Care Act to change the structures of incentive in support for the American health care system, so we can better support that seamless care. Right now in a fragmented payment system hospitals get rewarded, for example, for keeping their beds full. Doctors get rewarded for doing as much as they can. We’re, shifting that game. It now becomes not how much you do but how well you do, that determines the rewards you get and the support you get from us at CMS.

That’s really what doctors and nurses and hospitals want to do anyway. What’s the idea behind an Accountable Care Organization, is to set up a structure, in which doctors and hospitals and others can join together and take responsibility for a group of patients, Medicare beneficiaries, who are attributed to them.

We watch the beneficiaries, we watch where they get their care and if they get the majority of their care from a group of doctors who want to form an ACO then those patients are attributed to the ACO. They still can go anywhere they want, it’s still a Medicare fee for services to the patient lost no choices. But now that ACO conformance say we want to take responsibility for these people that come to us for care, as the ACO then begins to better coordinate care for those people building more cooperation, investing in care coordination, adopting electronic records, working in such a way that people can stay out of the hospital and stay healthy.

What will happen is cost will fall and quality will go up and now in the Accountable Care Organization world they can share in the savings. We split the savings with them. Medicare keeps some, some goes back to the providers of care We don’t want them skimping on care and so we watch quality very closely. The ACO rule has in it 33 measures of quality that we’re going to track really closely, and all of the normal functions of anti-trust regulations and others are watching for good behaviors.

I think the provider community will rise to that. In the ACO rule we’re offering a range of options about how you can get into this shared savings environment all the way from the track one of the rule in which you’re allowed to share savings but you don’t have any downside risk if costs go too high, way over to the pioneer program, offered now by the center for Medicare and Medicaid innovation which you can actually share more savings but take more risk if costs go too high. In all cases we’re protecting the beneficiary but watching care very, very closely to make sure that it’s improvements that’s generating the savings that we can now share.

There’s lots of interest in this all over the country. We’re going to see ACOs of many forms develop and I’m pretty excited about getting this rule into final form. I’ve got to thank, literally hundreds of your colleagues, people all over CMS, all over HHS indeed, and other government agencies have been getting together to help shape this rule to download and read the over 1200 comments we got to travel all over the United States getting feedback so that the final rule can be much better than the proposed rule as indeed it is.

I think we have a really exciting program on our hands. Many of you will be called upon to explain this rule to beneficiaries, to your friends and neighbors and your family. Now I’d like to make sure you have all the information you want about this. So log on to or find other ways to get information, inform yourselves and we’ll be reaching out with information to CMS employees so you can understand this wonderful, wonderful new program.

It’s part of the transition to the American health care system we want, which is really supporting care, to keep people healthy and which the whole structure of care shifts from volume to value from how much you do to how well the patient does and that’s what the ACO is intended to do. It’s a pretty exciting day. Thanks.

For the complete video and original transcript posted, click here.


Proposed v. Final ACO Rule

By Gregg A. Masters, MPH

Deep in the 690+ pages of the document filed with the OFR, is a nifty little matrix that compares key provisions of the ‘notice of proposed rule making’ to the final rule which theoretically incorporated the best and brightest suggestions pro-offered in 1,300+ comments supplied to CMS.

That pre/post matrix can be accessed here. It is a good cheat sheet to follow along with some of the key provisions providing a fair amount of ‘stakeholder heartburn’.

In the end, and in the hard to please everyone department, AMA acknowledges CMS for reducing the number of quality measures, while ASCO expresses it concern over their reduction and failure to reflect the QM measures specific to oncology.


ACOs: It’s Not Just About Medicare [shared savings]

By Gregg A. Masters, MPH

A recent report attached to a Tweet posted by Brian Ahier caught my attention in the blitzkreig of ACOs postings this past week.

 @ahier Building #ACO‘s & OUtcome Based Contracting in the Commercial Market

The complete title of the attached report is ‘Building ACOs and Outcome Based Contracting in the Commercial Market: Provider and Payor Perspectives‘.

This immediately caught my attention as for the better part of 30 years in the healthcare industry I spent a considerable amount of time in the managed care contracting business negotiating and signing my share of upstream (payor) as well as (downstream) hospital, physician and network agreements. From full risk, global capitated network deals to discounted fee for services to specialty care subcontracting and essential re-insurance backstops, I lived and breathed c/o/n/t/r/a/c/t/i/n/g.

Since the release of the proposed rule to implement the ACO provisions in the Affordable Care Act, most of the mainstream discussion has been about the ‘Medicare Shared Savings Program’, and considerably less attention has been paid to the activities delegated to the Center for Medicare and Medicaid Innovation (CMMI).

This report may change that singular focus since it broadens the loop and recognizes the market shift which is and has been rather active since the passage of the Act in March of 2010.

Call it ‘managed care 2.0, or 3.0’ or whatever you choose, the fix in healthcare, i.e., bending the cost curve. demonstrating the value proposition and improving access while reducing the rate medical inflation, if not lowering the cost of care, is rather well known: integration (legal, financial and operational) of medical practices under a banner of patient centered and coordinated (v. solo-ed or fragmented) care, enabled by information networks linked and seamlessly integrated across the continuum of care.

This was the same mission in the 70s and 80s when primarily HMO’s and to a lesser degree PPO’s were the mantra, yet the pain points did not exist as they do today, nor did the enabling technologies. The difference today is our house of cards sick care system is in the ICU on life support, and no one is defending the more is better, fee for services paradigm that drove our ‘healthcare borg’ to these heights of inefficiency and diminishing returns. Yet technology along with a determined shift in consciousness if not the sober recognition that ‘business as usual’ is not an option, gives us a materially different palette on which to collaborate towards a changed paradigm.

Check out this report and see what is already happening below the radar. You might be surprised. There is enough here to parse out over several posts and perhaps even invite the authors into a conversation on ‘ACO Watch: A Mid-Week Review’.