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CMS Pressed to Extend Deadline on Pathways to Success Applications

Analysis  |  By John Commins  
   January 21, 2019

Stakeholders say the existing February 19 application deadline for the Medicare Shared Savings Program 'will be challenging, if not impossible' to meet.

Key stakeholders including the American Medical Association and the American Hospital Association are urging federal policymakers to extend by at least one month the application deadline for the new Pathways to Success program.

CMS released the 267-page final rule for Pathways to Success under the Medicare Shared Savings Program in late December, and announced earlier this month that applications to participate in the program would be due February 19.

The provider associations say that's not enough time.

"Due to the complexity of CMS's new final rule for the program published in the Federal Register on December 31, 2018, many existing ACOs and those in the process of formation are still actively working to understand how they may successfully participate in the program," they wrote in a joint letter Friday to Centers for Medicare & Medicaid Administrator Seema Verma.

The stakeholders asked Verma to push back the deadline until at least March 29. The MSSP begins on July 1.

"Additional time is needed to ensure ACOs may evaluate their options and complete the administrative and legal requirements of the application. Without additional time, participation in this voluntary program will suffer," the letter said.

The organizations that signed the letter include the AHA, AMA, American College of Surgeons, America's Essential Hospitals, the American Academy of Family Physicians, the Federation of American Hospitals, the Medical Group Management Association, the Association of American Medical Colleges, and the National Association of ACOs.

NAACOS had already pressed CMS to extend the deadline in a January 10 letter to Verma.  

The other stakeholders climbed on board after noting that successful ACOs "are not typically a single entity but rather a network of different providers affiliated under the legal umbrella of the ACO including physician groups, hospitals, and skilled nursing facilities."

"To be successful, ACOs need time to obtain buy-in from ACO entity participants, boards and leadership regarding new or continued participation," the letter said. "Some ACOs can include nearly 200 unique sets of providers and must secure sign-on from multiple boards and governing bodies before finalizing applications."   

NAACOS in its comments to the August proposed rule recommended CMS allow ACOs with agreements expiring in 2018 to extend through December 31, 2019. NAACOS last June urged CMS to provide information regarding the expected timeline for 2019 applications so that organizations may begin to prepare for a condensed application period. 

The February 19 deadline applies to new ACOs, ACOs whose agreements expired at the end of 2018, and ACOs who want to end their current agreements and start under the new Pathways structure.

ACOs with three-year agreements that expire at the end of 2019 or 2020 are allowed to finish those contracts before starting in the new structure.

The condensed deadline comes as ACOs also contend with a March 1 deadline to apply for CMS's Bundled Payments for Care Improvement Advanced Model.

“Without additional time, participation in this voluntary program will suffer.”

John Commins is a content specialist and online news editor for HealthLeaders, a Simplify Compliance brand.


Provider associations ask CMS Administrator Seema Verma to extend the MSSP deadline to March 29.

Applicants seek more time to complete complex administrative and legal requirements.

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