Will ACO REACH be the right APM model for providers?

Can ACO REACH help CMS and providers achieve the unmet goals of prior alternative payment models? If so, a stronger focus on equity, provider leadership, accountability through risk and evaluation may make the difference.

Announced Feb. 24, ACO REACH — Accountable Care Organization Realizing Equity, Access, and Community Health — is CMS' newest voluntary APM. Robust resources and capabilities will be needed to navigate its requirements.

As highlighted in a recent CMS webinar, ACO REACH is the first APM to launch following a Strategy Refresh by the Center for Medicare and Medicaid Innovation. ACO REACH aligns with the CMMI objective of driving accountable care to improve cost and quality and will replace the current Global and Professional Direct Contacting program, effective Jan. 1, 2023. CMMI encourages current GPDC participants and new entrants to apply, noting that selection criteria and performance monitoring will be more stringent.

This blog highlights key differences between GPDC and ACO REACH, along with topline data and analytics implications.

ACO REACH priorities

As noted in a prior DataGen blog, only six of about 50 CMS APMs have produced significant savings. This must change for value-based design to help create a lasting impact on healthcare affordability, access, quality and equity.

CMS hopes that ACO REACH will be part of that equation and help launch a new decade of value-based design marked by:

• a greater focus on health equity, especially for underserved populations;
• stronger provider leadership; and
• more "robust screening, monitoring, and transparency."

CMS intends to have all Part A and B Medicare beneficiaries enrolled in APMs by 2030. Data management rooted in an analytics-forward approach and strengthened by social determinants of health intelligence can help providers with the long preparation and administration cycles required by ACO REACH and other APMs.

Requirement: Health equity

ACO REACH also aligns with a second CMMI objective: Advance health equity.

The goal? According to CMMI: "Embed health equity in every aspect of CMS Innovation Center models and increase focus on underserved populations." ACO REACH "will require participants to collect and report the demographic data of their beneficiaries and, as appropriate, data on social needs and [SDOH]. This includes data on race, ethnicity, language, geography, and disability."

An upcoming DataGen blog will detail ACO REACH's full health equity requirements.

• How ACO REACH differs from GPDC: ACO REACH adds five requirements related to health equity planning, data, associated care delivery and benchmarks. "Discrete points" to measure provider experience in these areas will be part of ACO REACH application scoring.
• Data and analytics implications: Embedding health equity does not happen overnight. Collecting and standardizing REaL (race, ethnicity and language) and SDOH data is a longstanding challenge. Providers need strategies, platforms and capabilities to integrate and analyze these data alongside existing metrics.

Requirement: Provider leadership

As noted above, CMS wants savvy providers to join ACO REACH. This includes practices "with demonstrated direct patient care experience and/or demonstrated successful experience furnishing high quality care to underserved communities."

For providers who meet these criteria but may be less skilled with APM administration, ACO REACH includes a New Entrant category. While all participants must take on downside risk, two options are available: Professional-50% or Global-100%; the latter may select primary care capitation only or assume risk for total care capitation.

Any APM requires strong provider leadership. With ACO REACH, CMS has increased provider governance requirements to help ensure that the shift from volume- to value-based design is led by those with the most to gain and lose besides patients: physicians.

• How ACO REACH differs from GPDC: ACO REACH requires that providers represent 75% (versus 25%) of their ACO governing board voting rights.
• Data and analytics implications: ACO REACH will need invested physician sponsors who think with an analytics-forward approach in concert with internal experts and external partners.

Requirement: Accountability

With great opportunity comes great responsibility. ACO REACH will ask much of its participants, who must acquire and submit more data, including on health equity, and in alignment with another CMMI objective: "Strengthen data collection and intersectional analyses … in order to identify gaps in care and develop interventions to address them."

Through ACO REACH, CMS is "strengthening its monitoring and compliance through improvements to its auditing, data analytics, claims analyses, and beneficiary outreach." The agency will also do more to help. In line with another CMMI objective, CMS will foster innovation through "actionable, practice-specific data, technology, dissemination of best practices, [and] peer-to-peer learning collaboratives," among other supports.

• How ACO REACH differs from GPDC: ACO REACH will significantly increase screening, monitoring and transparency compared to prior APM programs.
• Data and analytics implications: Monitoring and evaluation will be amplified under ACO REACH and future APMs. Providers will need a path to prepare for, continue and finish strong on auditing requirements.

Getting ready

In a recent article in Physicians Practice, DataGen's senior director of analytics, Alyssa Dahl, highlighted three critical challenges for providers considering APMs: resource constraints, program requirement complexity and data management. With assistance from CMS and analytics partners, ACO REACH could be a model that helps providers navigate these challenges and move more confidently toward alternative payments.

Providers considering ACO REACH can apply through April 22, 2022. CMS will announce participants in June in advance of the program's Jan. 2, 2023 start date.