In a notice published on its website on May 17, 2011, the Center for Medicare and Medicaid Innovation at the Centers for Medicare and Medicaid Services (CMS) requests comments on whether under its proposed rule for Medicare Shared Savings Accountable Care Organizations (ACOs), ACOs could receive advance payments of potential shared savings.   This change would be a significant amendment to the proposed rule for Medicare Shared Savings ACOs, which now includes retrospective payments AND a 25% withhold of any earned shared savings (to ensure capacity to pay any losses).   However, CMS has not amended the proposed rule, which has comments due on June 5, and instead has requested comments on this issue separately, due June 17.

The notice reads:

The Innovation Center is considering an Advance Payment Initiative for those ACOs entering the Medicare Shared Savings Program to test whether and how pre-paying a portion of future shared saving could increase participation in the Medicare Shared Savings Program.  Some providers have expressed a concern about their lack of ready access to the capital needed to invest in infrastructure and staff for care coordination. Under the proposed initiative, eligible organizations could receive an advance on the shared savings they are expected to earn as a monthly payment for each aligned Medicare beneficiary.  ACOs would need to provide a plan for using these funds to build care coordination capabilities, and meet other organizational criteria.  Advance payments would be recouped through the ACOs’ earned shared savings.

The Innovation Center welcomes reactions and suggestions from the public on this potential effort which may be electronically submitted to: advpayACO@cms.hhs.gov

Comments are due June 17, 2011.

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