September 6, 2018

Hello MaineHealth ACO Participants,
 
The clouds and fog had a low ceiling that day, and as the plane took off from the Portland Jetport runway, it was immediately enveloped by the low lying bank of mist that's typical for a coastal summer Maine morning. On that 737 was my 15 year old son who was flying across the country to spend two weeks hiking in the wilds of Wyoming and Idaho with only a 50 pound backpack carrying the bare necessities of food, clothing, and shelter.

Our teenager lives in the age of advanced technology and continual connectivity. Getting him "off-grid" for two weeks on a National Outdoor Leadership School (NOLS) course in an isolated and distant mountain range with a team of people he had never met before was a calculated decision; one that was fraught with a profound mixture of thrill of the unknown, confidence in a program that had 50 years of experience, but tempered by the knowledge that the courses have inherent risks and do not always unfold as planned.

For us as parents, watching the plane disappear into the great unknown flooded us with feelings of uncertainty and anxiety. We knew we had made a sound decision to send him off but it really felt like he had disappeared into a grey cloud detached from technology and the world of the familiar.

In early August, the Centers for Medicare & Medicaid Services (CMS) delivered a similar "journey into the unknown." Last April, we had made the decision as a system to advance our employed physicians and York Hospital to the Medicare Shared Savings Program (MSSP) Track 1+, an advanced APM (alternative payment model) that allowed us to remain in MSSP and continue with our strategy of moving to downside financial risk. At the same time, we decided to form a new corporation to re-apply to Track 1, the "upside only" track, for our private practices and St. Mary's. Our decision to choose Track 1+ offered an opportunity to earn greater shared savings than Track 1 (our current track) when targets are met, yet imposed a financial penalty if targets are missed. We had spent months assessing the CMS options and planning for this future journey.

But as if from an overhanging cloud bank, CMS delivered a seismic shift in the approach to the program on August 9, 2018. Recommending sweeping changes to the MSSP program, CMS released a Notice of Proposed Rulemaking (NPRM), titled Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations--Pathways to Success , containing significant changes to the Medicare Shared Savings Program (MSSP). 

In general, CMS has proposed an overhaul that eliminates all current MSSP tracks (e.g.: Track 1, 1+, 2, 3) and has written a new proposed rule that would delay/change our January 2019 start date to July 2019. The " Pathways to Success" program proposed changes include:
  • Elimination of all current MSSP tracks and formation of Basic and Enhanced Tracks
  • Delays January 1, 2019 agreement to July 1, 2019
  • Offers extension of current upside-only agreement through June 30, 2019
  • Accelerates pathway to downside risk
  • Extends agreement period from 3 to 5 years
  • A potential pathway for us will be one that closely resembles our recommendation to move to Track 1+
There is a 60 day comment period.  We know that the National Association of ACOs, Premier and other advocacy groups will weigh in heavily, and we do not know yet whether there will or will not be any significant changes to the proposed rule. If the proposed rule is adopted, we will respond with a new MSSP strategy that determines the optimal path for our ACO Participants, including our employed and private practices. In fact, the ACO management team and the MaineHealth ACO Board are in the midst of sorting through what this new "50 pound backpack" will hold or not hold, and we will be ready to course correct and continue to face the new round of uncertainty with a thoughtful plan and response to the needs of all our ACO Participants. Please be sure to check our MaineHealth ACO website and ACO newsletters with up to date information and helpful links.

My son did successfully make it back from a profoundly life-changing experience in the Wyoming Range. His stories of survival, camaraderie, new friendships, hailstorms, and nights sleeping under the vast big skies of the Tetons will be part of him forever. Capabilities to face the unknown, course correct when needed, and rely on learned experiences and knowledge will guide him. We are doing the same as we traverse changes in health care and lead the transformation with our learned knowledge, shared community and willingness to ascend into whatever kind of fog bank might hover. I am grateful for your camaraderie and look forward to forging the new path ahead.
 
Yours in health,
 
Elizabeth H. Johnson, MD, MS, FACP
President & Chief Executive Officer
MaineHealth Accountable Care Organization
EHJohnson@mmc.org |  (207) 482-7050