July 23, 2020
The Center for Medicare and Medicaid Innovation (Innovation Center) announced today that a new Frequently Asked Question, found below, has been released addressing stakeholder concerns about 2021 participation in the Next Generation ACO Model (NGACO), the Medicare Shared Savings Program, and Direct Contracting (Professional and Global Options).
Q. Our organization is currently an ACO in the Next Generation ACO Model (NGACO) or the Medicare Shared Savings Program for 2020. What is the deadline for deciding between NGACO, Shared Savings Program and the Direct Contracting Model for 2021 participation? Since PY1 for the Direct Contracting Model doesn’t start until April 1, 2021, can I participate in NGACO or the Shared Savings Program from January-March of 2021 before switching to the Direct Contracting Model for the rest of the year?
A. For ACOs participating in NGACO during 2020 that are deciding between NGACO and Direct Contracting for 2021 participation, the deadline to decide is 10/23/20 (when final DC participant provider lists are due for 2021). For ACOs participating in the Shared Savings Program during 2020 that are deciding between the Shared Savings Program and Direct Contracting for 2021 participation the deadline is 9/22/20 (when final ACO participant lists are due for ACOs participating in the Shared Savings Program in 2021). While we try to offer entities as much flexibility as possible to make participation decisions, there are operational limitations that require this decision deadline to be linked to the deadline for submission of final participant lists. Claims-based alignment, which functions similarly across these initiatives, aligns beneficiaries to the entity whose participating providers and suppliers have provided the plurality of the beneficiary’s primary care within a lookback period. By definition this is a competitive process since the amount of primary care provided to a given beneficiary is compared across health care providers both in and outside of each initiative. As a result, alignment within one initiative can affect alignment within other initiatives. Accordingly, alignment (specifically provider overlaps) for entities participating in Performance Year 1 of the Direct Contracting Model needs to be run prior to when NGACO and the Shared Savings Program begin their 2021 performance years (January), despite Performance Year 1 of the Direct Contracting Model not starting until April 1, 2021.
Given the above, entities are not able to participate in NGACO or Shared Savings Program in the first quarter of 2021 before switching to Direct Contracting. Entities that choose to participate in Direct Contracting in 2021 will therefore not be participating in the performance period of any initiative from January-March of 2021. However, we note that eligible clinicians in such entities may be able to become Qualifying APM Participants (QPs) under the Quality Payment Program based on performance measured on the June 30, 2021 and/or August 31, 2021 snapshot dates.
Stakeholders are encouraged to monitor the Direct Contracting webpage (https://innovation.cms.gov/innovation-models/direct-contracting-model-options) for future updates. Please email the Direct Contracting Model help desk with any questions or comments at DPC@cms.hhs.gov.