The Medicare Shared Savings Program (MSSP) is undergoing a major overhaul under the Pathways to Success regulation, finalized December 31, 2018. This regulation replaces the existing program participation tracks with an emphasis on increasing downside risk, as well as updates a variety of other program rules. This rule went into effect on January 1, 2019, with most aspects to be implemented fully starting July 1, 2019.
Though limited data is available on the 2019 MSSP cohort, it seems the vast majority of 2018 MSSP ACOs continued in the program. Track 1 (the upside risk-only option) has been eliminated, with most prior Track 1 ACOs transitioning to Track 1+. The true test remains how many MSSP ACOs will continue through the more substantial changes scheduled to begin on July 1, 2019 - and how many more might join.
New organizations and existing ACOs deciding whether to participate under the new rules will need to navigate a complex program that may have very different requirements and risk tracks depending on ACO makeup and history. ACOs with prior experience can expect to be shifted more quickly to downside risk, as can organizations whose Medicare revenue is at least a substantial portion of their assigned population's total expenditures.
To date, a strength of MSSP has been its reach in affecting the care of 10.5 million Medicare beneficiaries to help generate substantial annual savings. CMS is seeking to increase the intensity of savings performance by making punitive incentives more widespread, though in doing so may drive off organizations who might otherwise participate as part of the general shift to value-based payment and quality improvement. Ultimately it is yet to be seen how Pathways to Success will affect MSSP program participation, incentives for quality performance, and the overall breadth and impact of the program.