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MACRA Could Spawn Gentler Track for Downside Shared-Savings Risk

Analysis  |  By Christopher Cheney  
   October 24, 2016

A proposal to create a new track in the Medicare Shared Savings Program (MSSP) with limited downside risk is drawing guarded optimism from a pair of healthcare-provider trade associations.

As part of the 2017 final rule announced earlier this month for the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA), federal officials signaled their intention to create MSSP Track 1+.

Under current regulations, MSSP Track 1 bears no downside risk for accountable care organizations (ACOs); MSSP Track 2 and Track 3 feature both upside and downside risk.

"It is a pretty big jump in terms of downside risk to Track 2; so it would be helpful, particularly to retain ACOs that are already in the program, to give them something in between Track 1 and Track 2," says Melissa Myers, JD, MPA, senior associate director of policy for the Chicago-based American Hospital Association.


Give MSSP Track 1 Advanced APM Status, Researcher Urges


CMS provided few details about MSSP Track 1+ in the 2017 MACRA final rule, with only one paragraph on one page devoted to the proposal in the 1,746-page document.

That paragraph indicates CMS is considering "developing and testing a "'Medicare ACO Track 1+ 'Model" starting for the 2018 performance year".

The Track 1+ Model would test a payment model that incorporates more limited downside risk than in Tracks 2 or 3. CMS envisions Track 1+ as an on-ramp to Tracks 2 or 3. The model could be open to:

  • Track 1 ACOs that are within their current agreement period
  • Initial applicants to the Shared Savings Program
  • Track 1 ACOs renewing their agreement that meet model-eligible criteria

Christopher Cheney is the senior clinical care​ editor at HealthLeaders.


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