2. ACO Reach Participation
31 Dec. 2022
The GPDC Model will continue until December 31,
2022 and then transition to the ACO REACH Model.
1 Jan. 2023
Current participants in the GPDC Model must agree
to meet all the ACO REACH Model requirements by
January 1, 2023 in order to participate.
3. ACO Reach Participation
Mar 7 2022
The application portal will be available
beginning on March 7, 2022 and will close
at 11:59 PM Eastern Time (E.T.) on April 22,
2022.
June 2022
REACH ACO Selection
Aug 1 2022
Implementation Period until 12/31/2022 to
conduct voluntary alignment
Jan 1 2023
The first performance year of the
redesigned ACO REACH Model will start on
January 1, 2023, and the model
performance period will run through 2026.
Dec 31 2026
ACO Reach End
CMS is not soliciting Letters of Intent (LOIs) for PY2023
starters, therefore submitting an LOI is not required to
submit an application in response to this RFA. Nor do
current GPDC participants need to complete an
application.
4. Reach ACO Key Differences to Traditional ACO
Eligibility for those with insufficient number of aligned beneficiaries (5,000)
Two risk sharing and capitation options with participation options for participants and preferred providers
•Global or Professional risk sharing model
•Total Care Capitation (TCC) or Primary Care Capitation (PCC)
Claims-based quality performance
Health Equity Requirements
Split the TIN for participants (NPI participation)
•Splitting the TIN will be permitted, which will allow Participant Providers with separate NPIs who bill through the same TIN to join
separate models. In addition, a Participant Provider may participate in another model using another TIN that is not being used for
the ACO REACH Model. Does not apply to preferred providers
5. Minimum Number of Aligned Beneficiaries Required
at the Start of Each Performance Year
Standard: Minimum of 5,000 aligned beneficiaries prior to the start
of each performance year. Minimum of 3,000 beneficiaries that would
have been aligned during at least one base year (CY2017, CY2018, or
CY2019).
New Entrant: Minimum number of aligned beneficiaries prior to the
start of each performance year under the “glide path”: Beneficiaries
aligned via claims must not exceed 3,000 in any base year (2017-2019
• PY2021 (April-December 2021): 1,000 beneficiaries
• PY2022: 1,000 beneficiaries
• PY2023: 2,000 beneficiaries
• PY2024: 3,000 beneficiaries
• PY2025: 5,000 beneficiaries
• PY2026: 5,000 beneficiaries
High-Needs: Minimum number of aligned beneficiaries prior to the
start of each performance year under the “glide path”:
• PY2021 (April-December 2021): 250 beneficiaries
• PY2022: 250 beneficiaries
• PY2023: 500 beneficiaries
• PY2024: 750 beneficiaries
• PY2025: 1,200 beneficiaries
• PY2026: 1,400 beneficiaries
ACO Type
Standard
Experience with
beneficiaries
New Entrant
Limited historical
experience delivering
care to Medicare FFS
beneficiaries.
High Needs
Very high-risk
patients
6. CMS
Reach ACO
Global 100%
(Full Risk subject to risk
corridors)
Primary or Total Care Capitation
Participants
ACO Participant Providers for
alignment of beneficiaries and
mandatory capitation
Preferred Providers
Preferred Providers optional
capitation arrangements
Professional 50%
(Partial Risk subject to risk
corridors)
Primary Care Capitation
Participants
ACO Participant Providers for
alignment of beneficiaries and
mandatory capitation
Preferred Providers
Preferred Providers optional
capitation arrangements
Participant Provider claims
reduction: PY2021: 1-100%
PY2022: 5-100% PY2023: 10-
100% PY2024: 20-100%
PY2025: 100% PY2026: 100%
Participant Providers must
participate in 100% claims
reduction
Preferred Providers elect 1-
100% claims reduction
Primary Care Capitation (PCC) equal to 7% of
the PY Benchmark for enhance primary care
services (4% recoup) subject to a quality
withhold
Choice between PCC or Total Care
Capitation (TCC) equal to 100% of the
cost of care for aligned beneficiaries
subject to a discount and quality
withhold
7. Gross Savings/Losses
as a % of Final PY
Benchmark
(Professional
ACO Shared
Savings/Losses Cap
CMS Shared Savings
Losses Cap
Risk Band 1:
Gross Savings/Losses
Less than 5%
50% savings/losses 50% savings/losses
Risk Band 2:
Gross Savings/Losses
Between 5% and 10%
35% savings/losses 65% savings/losses
Risk Band 3:
Gross Savings/Losses
Between 10% and 15%
15% savings/losses 85% savings/losses
Risk Band 4:
Gross Savings/Losses
Greater than 15%
5% savings/losses 95% savings/losses
Gross Savings/Losses as a % of Final
PY Benchmark (Global)
ACO Shared
Savings/Losses
Cap
CMS Shared
Savings Losses
Cap
Risk Band 1:
Gross Savings/Losses
Less than 25%
100%
savings/losses
0% savings/losses
Risk Band 2:
Gross Savings/Losses
Between 25% and 35%
50%
savings/losses
50%
savings/losses
Risk Band 3:
Gross Savings/Losses
Between 35% and 50%
25%
savings/losses
75%
savings/losses
Risk Band 4:
Gross Savings/Losses
Greater than 50%
10%
savings/losses
90%
savings/losses
9. Five new policies to promote
Health Equity starting in PY2023
•Health Equity Plan Requirement
• REACH ACOs will be required to develop and implement a Health Equity Plan starting in 2023 to identify
underserved patients within their beneficiary population and implement initiatives to measurably
reduce health disparities
• Disparities impact statement as a guide
•Health Equity Benchmark Adjustment
• A beneficiary-level adjustment will be applied to increase the benchmark for those REACH ACOs serving
higher proportions of underserved beneficiaries in order to mitigate the disincentive for ACOs to serve
underserved patients by accounting for historically suppressed spending levels for these populations
• Atlas map
•Health Equity Data Collection Requirement
•Nurse Practitioner Services Benefit Enhancement
• Nurse Practitioners will be able to assume certain responsibilities or furnish certain services without
physician supervision that they typically could not under current Medicare law, to the extent permitted
under applicable state law Health Equity Questions in Application and Scoring for Health Equity
Experience
10. ACO Reach Benchmarking Methodology
• BY1, 2 & 3 will be 2017, 2018 & 2019 for all REACH ACOs including existing DCEs
• Benchmark includes a mix of historical claims experience and a regional rate book
• Trending, geographic adjustments, risk adjustments, discounts and incentives
• New- Health Equity Benchmark Adjustment
– Area Deprivation Index
– Dual Medicaid Status
– Top 10% receives a $30 PMPM positive adjustment
– Bottom 50% receive a $6 PMPM negative adjustment
11. Demographic and SDOH Data Reporting and Bonus
Demographic and SDOH Data Reporting and Bonus
REACH ACOs will be required to collect and report certain beneficiary-reported
demographic data and social determinants of health data on their aligned beneficiaries for
purposes of Model monitoring and evaluation.
In PY2023, completing the requirement to collect and report beneficiary-reported
demographic information will result in a bonus to the ACO’s quality score, but there will be
no downward adjustment for the failure to report this information.
In PY2024 and beyond, CMS may impose a requirement on ACOs to collect and report
demographic and social determinants of health data on their aligned beneficiaries that
results in a downward adjustment to the ACO’s quality score if not completed.
12. Discount PY2023 PY2024 PY2025 PY2026
Professional N/A N/A N/A N/A
Global (GPDC) 3% 4% 5% 5%
Global (ACO Reach) 3% 3% 3.5% 3.5%
Quality Withhold PY2023 PY2024 PY2025 PY2026
Professional and
Global (ACO Reach
2% 2% 2% 2%
Global (GPDC) 5% 5% 5% 5%
13. ACO Reach
Changes to Original GPDC
PY 2023 - Providers will have to control at least
75% of REACH ACO governing boards, compared
to 25% in GPDC and Medicare beneficiary and
the consumer advocate serving on the ACO’s
governing body are not permitted to be the
same individual and both must hold voting rights
The ACO REACH Model employs the ACO-
specific symmetric 3% risk score cap.
To further deter coding intensity, starting in
PY2024, the application of the symmetric 3% risk
score cap will be modified to: 1) adopt a static
reference year population, and 2) cap the ACO’s
risk score growth relative to the ACO’s
demographic risk score growth in determining
the ACO-specific 3% risk score cap thresholds
14. Why consider
ACO Reach
Model?
Options that offer flexibility
• PCC vs. TCC capitation
• Global vs. Professional risk
• Participant Provider selection at NPI level
• More effectively control spend using preferred provider
arrangements
Benchmarking methodology may be more favorable
to your organization
5% APM bonus for claims-based quality reporting
Claims-based quality reporting and performance
assessment reduces provider reporting burden
15. Tasks next week
Benchmark analysis for ACO Reach
Important to complete ACO Reach benchmark
analysis using ACO data to determine if ACO Reach
methodology is favorable for organization
Retain application preparation assistance and
preferred provider contracting assistance
Greg Shockey, greg@nationalendeavors.com