Yesterday, CMS announced the first batch of 27 “normal” ACOs under its Medicare Shared Savings Program (MSSP).
I found five things interesting about the list:
- 93% were unwilling to accept downside risk. In the original proposed rule for the MSSP, ACOs would have been forced to accept downside risk. Presumably, CMS thought that “skin in the game” would be an important motivator for real transformative change, and they wanted to increase the chances that the federal government would be able to achieve a net cost reduction. But, in response to fierce backlash from providers saying they did not want to accept downside risk, CMS relented and introduced an option allowing providers to avoid taking downside risk in exchange for a smaller upside reward. When it came time to lay chips on the table, 93% took the safe bet.
- Only 18% requested up-front payment. One of the complaints from the provider community during the design phase of the MSSP was that providers lacked access to the capital needed to create the infrastructure to successfully improve care processes and manage risk — things like healthcare information technology, analytics and care management. In response, CMS offered an option where ACO applicants could receive some up-front payments that would be repaid out of subsequent rewards. CMS was offering to finance the investment, but it would be a loan, not a grant. Only 18% of the first batch of ACOs selected this option. I suspect this was due to the same risk aversion that led them to accept smaller rewards to avoid downside risk.
- 33% used payer-based infrastructure. If physician organizations are to remain locally-focused, it makes more sense to share infrastructure with others to achieve economies of scale, rather than taking on the cost of creating their own infrastructure. As I described in a prior post, this can be accomplished through a franchise arrangement. It can also be accomplished through a management services organization (MSO), as is commonly done by PPOs and medical groups in mature managed care markets. Or, it can be done by partnering with payers who already have such infrastructure. Any of these approaches could potentially work, but I’m least enthusiastic about using payers’ infrastructure. Nevertheless, nine of the 27 new MSSP ACOs are organized as partnerships between local health care providers and Collaborative Health Systems (CHS), a division of Universal American, a publicly-traded for-profit health insurance company that offers a variety of plans including Medicare Advantage plans. For these 9 ACOs, Collaborative Health Systems will provide a range of care coordination, analytics and reporting, technology and other administrative services. This is a popular option not only because of the economies of scale, but also because it allows the providers to avoid having to take out a loan, either from CMS or from traditional sources of capital such as banks or the equity markets.
- 44% did not note the number of physicians in their press-release blurb. I hate to read too much into such a factoid. But, for ACOs to work, the physicians must really be involved. What does it tell you if the organizers of an ACO, when drafting their little blurb for the CMS press release announcing their selection as one of the first batch of MSSP ACOs, did not think to state the number of physicians involved?
- Average beneficiaries per physician is 107. Of the 13 ACOs that did think to include the number of physicians in their press release blurb, 4 of them had between 100 and 400 beneficiaries per physician, 7 of them had between 31 and 60 beneficiaries per physician, and 2 of them had less then 10 beneficiaries per physician. If ACOs are to really work, they don’t just need infrastructure, they need “mind share.” If 5% of your patients are involved in some new program, and if you have not agreed to any downside risk in terms of taking on debts or being on the hook for possible negative rewards, and if the rewards are relatively small even for that 5% of your patients, are you really going to be motivated to radically transform your care processes and change your habitual clinical decision-making practices?
Here’s this list, including the beneficiaries per physician calculations.