Medical Advantage (MA) recently announced the launch of the new Advantage Medicare Shared Savings ACO (Advantage ACO) for primary care practices in Michigan, Ohio, Indiana, Kentucky, Tennessee, Alabama, and Florida. The ACO goes into effect January 1, 2022.
The Advantage ACO offers numerous advantages to participating practices. These include the ability to increase revenue through shared savings, as well as 1:1 training and support in areas ranging from Annual Wellness Visits to advanced care planning, billing and coding, care management, risk adjustment, and transitions of care. With no ACO fees and no downside risk for participating practices, there are virtually no drawbacks for practices who are interested in participating.
Among the many advantages of joining the Advantage ACO, participants will enjoy significant benefits related to the Merit-based Payment System (MIPS). MIPS is one of two tracks of the Quality Payment Program (QPP) run by the Centers for Medicare and Medicaid Services (CMS). The second track of QPP is Alternative Payment Models (APMs), which is where the Advantage ACO comes in.
The Advantage ACO will be a MIPS APM for the 2022 reporting period of QPP. MIPS APMs and their participating clinicians must still report MIPS, but they are able to take advantage of special reporting and scoring standards that do not apply to clinicians reporting at the individual or group level.
The table below summarizes the differences in reporting requirements for eligible clinicians reporting independently as opposed to reporting through the Advantage ACO.
|Practice Reporting Requirements in 2022|
|Traditional MIPS reporting requirements.||MIPS APM reporting requirements.|
|Quality*||Report 6 self-selected clinical quality measures, including one outcome or high priority measure.||Report 3 required APP clinical quality measures: Diabetes: HbA1c Poor Control Controlling High Blood Pressure Screening for Depression and Follow-up Plan|
|Promoting Interoperability||Report on 5-6 required measures and an optional bonus measure, unless excluded by automatic or approved reweighting.||Same as traditional MIPS path.|
|Improvement Activities||Implement and attest to 2-4 activities.||No reporting necessary. Advantage ACO participants receive automatic full credit in this category.|
|Cost||Applicable measures calculated based on administrative claims data. Cost will account for 30% of MIPS final score.||Category excluded for MIPS APM participants. Points are re-distributed to Quality and Promoting Interoperability.|
*MIPS APM Entities are also scored on a CAHPS patient satisfaction measure and two administrative claims measures for the Quality category, but those measures do not require tracking or reporting by the participating practices. For a full list of all Quality measures for MIPS APMs , please see here.
As you can see above, reporting for Promoting Interoperability stays the same for both types of reporters, but there is significantly reduced burden in the Quality and Improvement Activities categories under the new APM Performance Pathway (APP). The APP is a streamlined reporting model available only to APM Entities – such as the Advantage ACO – and their participants. The APP is designed to reduce MIPS reporting burden through a single, pre-determined measure set focused on high priority and aligned metrics.
Administrative burden is the number one complaint we hear from clinicians and practices seeking MIPS consulting. Between keeping up with complex reporting requirements that change annually and the never-ending tasks of documentation and monitoring, practices are investing more time and resources in MIPS each year. That burden will only get heavier in 2022, the first year of MIPS in its full implementation as dictated by the Medicaid Access and Chip Reauthorization Act (MACRA).
CMS no longer has the authority to alter reporting and scoring standards to make the program easier for clinicians. One notable change in 2022 is that the performance threshold must be set at the national mean or median of a prior MIPS performance year. The lowest mean or median to date was 74 points — the mean for 2017. A performance threshold of 74 sets a high bar, and a lot of burden, for clinicians simply to avoid penalties – let alone earn incentives.
Participants in the Advantage ACO will experience relief from this burden in two ways. First, Advantage ACO participants will be able to take advantage of the simplified reporting standards outlined above. Second, Medical Advantage is committed to providing educational and consulting support to all participating practices to ensure excellent MIPS performance across the ACO. Medical Advantage has a proven track record of helping our MIPS consulting clients achieve exceptional performer status and maximum incentives since 2017. This MIPS assistance will be especially valuable for providers coming out of the Comprehensive Primary Care Plus (CPC+) program at the end of the year, as these clinicians have not been required to report MIPS in the past and may be at increased risk for penalty as they compete against experienced reporters.
In 2023 and beyond, when the Advantage ACO is expected to achieve Advanced APM status by taking on risk in the MSSP contract, participants have even more to gain related to QPP. Participants in an Advanced APM who receive a certain threshold of payments or see a certain threshold of patients through the Advantage ACO, will receive Qualifying Participant (QP) status from CMS. QPs in an Advanced APM are exempt from MIPS and automatically receive a 5 percent bonus on Medicare Part B revenue annually. This means reporting burden decreases even more, while potential revenue increases above levels historically available in MIPS. In addition, in 2026 and 2027, Advanced APM participants are scheduled to receive an additional 0.75 percent Medicare fee schedule increase vs. the standard scheduled 0.25 increase for all other providers.
If you would like to discuss the MIPS advantages of the Advantage ACO specific to your practice circumstances, or learn more about the Advantage ACO in general, contact one of our physician group consultants today.