On Feb. 24, 2022, the Centers for Medicare and Medicaid Services (CMS) announced the redesign of its Global and Professional Direct Contracting (GPDC) accountable care organization (ACO) into one that focuses on health equity. The redesigned model, Realizing Equity, Access, and Community Health (REACH), was modified to reflect the Biden administration’s policy priorities as well as stakeholder feedback and participant experience.
REACH will focus on: health equity to bring the benefits of ACOs to underserved communities, promoting provider-led organizations, protecting beneficiaries with increased screening of model applicants, increased monitoring of model participants, and greater transparency and data sharing.
Key governance changes in REACH include increasing the proportion of participant providers in the governing body to 75 percent, and prohibiting the same individual from serving as both the Medicare beneficiary and consumer advocate. Additionally, the Medicare beneficiary and consumer advocate must have voting rights – effectively enhancing the goal of creating patient-centered delivery models. The increased proportion of provider leadership aligns REACH with the governance requirements in other CMS-approved alternative payment models.
REACH offers two risk-sharing options:
The lower risk-sharing professional option (50 percent of savings/losses), in which the ACO receives a primary care capitation payment and a risk-adjusted monthly primary care payment.
The higher-risk global option (100 percent of savings/losses), which has two payment options. ACOs electing the global risk option may choose to receive a primary care capitation payment or a risk-adjusted total care capitation payment for all covered services provided by the ACO’s providers.
A summary table comparing GPDC to REACH can be found here.
GPDC will continue until Dec. 31, 2022, and then will transition to the REACH model. REACH will run through four performance years beginning on Jan. 1, 2023. Current participants in the GPDC model are not required to apply and will be accepted into the REACH model if they have a strong compliance record and agree to comply with new REACH requirements.
CMS will accept REACH applications March 7, 2022 through 11:59 p.m. EST on April 22, 2022. The request for applications can be found here. CMS also announced it is canceling the Geographic Direct Contracting Model, which was announced in December 2020 by the Trump Administration but was paused in March 2021.
© 2022 Dinsmore & Shohl LLP. All rights reserved.National Law Review, Volume XII, Number 67