ACOs and more advanced risk-taking models

Accountable care organizations (ACOs) that participate in the Medicare Shared Savings Program (MSSP) take on a certain level of risk, depending on the track they choose. There are three track levels, each with an increased amount of risk involved. Most ACOs choose Track 1, which has the lowest level of risk. In fact, in 2018 there are 561 Medicare ACOs in the program and 82% of them remain in Track 1.

The Centers for Medicare & Medicaid Services (CMS) recently implemented a Track 1+ as a time-limited CMS Innovation Center model. An ACO must concurrently participate in Track 1 of the Shared Savings Program in order to be eligible to participate in the Track 1+ Model. The Shared Savings models are currently:

Track 1 – Track 1 ACOs do not assume downside risk (shared losses) if they do not lower growth in Medicare expenditures.

Medicare ACO Track 1+ Model – Medicare ACO Track 1+ Model (Track 1+ Model) ACOs assume limited downside risk (less than Track 2 or Track 3).

Track 2 – Track 2 ACOs may share in savings or repay Medicare losses depending on performance. Track 2 ACOs may share in a greater portion of savings than Track 1 ACOs.

Track 3 – Track 3 ACOs may share in savings or repay Medicare losses depending on performance. Track 3 ACOs take on the greatest amount of risk but may share in the greatest portion of savings if successful.

According to CMS regulations, ACOs that began in Track 1 in 2012 or 2013 must move to a risk-based model by their third contract periods, which begin in 2019. A National Association of ACOs survey found that 71% of the ACOs that began their MSSP participation in those years are “likely to leave the MSSP if they must assume risk.”

The Association has asked CMS to consider revising its regulations, allowing ACOs to continue their participation in Track 1 an additional three years. Over two-thirds of the Association’s survey respondents said they would remain in the MSSP if the changes were made. The ACOs say “they need more time without risk because MSSP regulation has changed considerably since the early years and ACOs are just now operating successfully.”