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The little-known consequences of the 2021 ACO rules

ACOs know that the 2021 Proposed Rule[1] has brought a number of changes to ACO participants, including the removal of the CMS Web Interface reporting option.

While many ACOs are relieved this option remains in effect for 2021, few have understood the underlying realities of this change.

In an effort to reduce burden by streamlining activities across various quality and payment models, beginning in 2022, CMS will require MSSP ACOs to report on a single set of 6 measures. That set of 6 measures is made up of survey, administrative, claims, and 3 measures the ACO will need to “actively report.” Simple, right?

The challenge is, that those 3 “active reporting” quality measures are essentially MIPS CQM / eCQM measures that include all-payer patients as the reportable population. In order to remain competitive, ACOs must now examine implementing change across all payers starting in 2022.

For ACOs made up of 100s of otherwise unaffiliated TINs, each with its own set of billing and clinical systems, this could be a big deal.

Adding further complexity, ACOs and their member organizations will also have the choice of submitting quality data at the ACO, participating TIN, or NPI level. Participating TINs and providers could also choose to submit data for MIPS even though they are included in ACO-level reporting. This complexity was intended to provide alternatives for reporting in the case(s) where large (multi-facility) ACOs faced interoperability and/or accessibility constraints to organizations within their ACO.

At this point, many ACOs are realizing that in order to thrive in this changing landscape, they should reexamine the resources necessary to support member practices and the financial objectives of the organization.

Leveraging technology in the right way can lead to operational improvements and efficiencies that allow ACOs to actively manage each step of the patient experience.

ReportingMD brings clinical, claims, social and other disparate data sources together into one system, providing a 360-degree view of performance. We can help you to find the best possible reporting avenue for your organization and help you establish a winning strategy for the future. With 18-years’ experience and a helpful team of healthcare analytic experts – we do the work, so you can focus on patients.

ACOs without a plan in place when 2022 begins will have little control over their performance. While those that use this transition year to formulate a strategy, will reap the savings.


[1] Physician Fee Schedule (PFS) Proposed Rule, 85 FR 50074, Federal Register (2021). https://www.federalregister.gov/documents/2020/08/17/2020-17127/medicare-program-cy-2021-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

About the author

Molly Minehan is ReportingMD’s Director of Client Services and Innovation

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