February 27, 2024  – In an attempt to further redefine healthcare delivery, the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) and the National Association of ACOs (NAACOS) have outlined a series of strategic recommendations aimed at increasing the participation of long-term and post-acute care (LTPAC) providers in Accountable Care Organizations (ACOs). This initiative targets the integration of LTPAC providers into value-based care arrangements to ensure a more cohesive and effective healthcare system.

LTPAC providers currently encounter hurdles in joining ACOs, primarily due to misaligned policies. These challenges include defining accountable patient populations, setting financial benchmarks, and measuring quality in a way that resonates with the unique nature of long-term care services. Notably, less than 10 percent of skilled nursing facilities (SNFs) nationwide are engaged in ACOs. This figure shows the urgent need for policy adjustments to encourage broader participation so patients can get the value-based care that they deserve.

The collaboration between AHCA/NCAL and NAACOS brought together a diverse group of stakeholders for an in-depth discussion on potential reforms. This included LTC representatives, ACOs, payers, providers, and even patient advocacy groups. The consensus highlighted the necessity for the Centers for Medicare & Medicaid Services (CMS) to adjust its approach to value-based arrangements, ensuring that LTPAC providers can seamlessly integrate into the ACO framework.

Key recommendations include:

• Alignment and Participation Enhancements: Modify current practices to better align LTPAC beneficiaries with ACOs by removing long-term care Nursing Facility (NF) populations from the Medicare Shared Savings Program (MSSP) to avoid misalignment. 
• Financial Methodology Adjustments: Ensure the reference population for ACOs includes a comparable rate of institutionalized patients. Adopt the current risk adjustment model being tested in the ACO REACH for the SNF/NF population to ensure accurate financial benchmarks.
• Quality Measurement Optimization: Implement a set of quality metrics tailored to the needs of the SNF/NF population, focusing on measures that promote effective care transitions, discharge planning, and advanced care planning to enhance the quality of care and reduce unnecessary hospital visits.
• Data Sharing and Infrastructure Improvements: Enhance the Medicare system to identify ACO attribution for beneficiaries, share performance data more regularly with ACO participants, and provide more comprehensive utilization and cost data. Additionally, leverage data-sharing networks for real-time information exchange and work towards the integration of NF/SNF records with other healthcare providers.
• Support for Future Model Concepts: Develop a voluntary episode-based payment model for SNF providers within an ACO framework, addressing healthcare delivery system challenges, ensuring scalability, and providing meaningful incentives for participation. This model should align with the strategic vision of the Center for Medicare and Medicaid Innovation (CMMI) and prioritize data sharing to facilitate participation.

To support these recommendations, stakeholders suggest leveraging data-sharing networks for real-time information exchange and providing additional funding and technical assistance to facilitate the integration of SNF and physician records. These measures are envisioned to bridge the gap between acute care and long-term care providers.

These strategic recommendations represent a concerted effort to align CMS’s policy framework with the operational realities of providers. By adopting these measures, CMS can pave the way for a more inclusive, efficient, and patient-centered healthcare system, where providers play a pivotal role in delivering coordinated, high-quality care.