The Centers for Medicare & Medicaid Services (“CMS”) recently announced the ACO Realizing Equity, Access, and Community Health (“REACH”) Model. The ACO REACH Model is designed to replace the Global and Professional Direct Contracting (“GPDC”) Model, which we previously discussed here.
The application period for the ACO REACH Model opens Monday, March 7, 2022, and closes April 22, 2022, with an effective date of January 1, 2023. Despite its short application window, the ACO REACH Model presents big opportunities for existing ACOs and those entities that had intended to participate in the GPDC Model.
Background
Building on the framework of the GPDC Model, CMS has indicated the ACO REACH Model is intended to achieve the following six strategic pillars: advancing health equity; expanding access to quality and affordable health coverage; engaging partners; driving innovation; protection of government health care programs; and fostering excellence. In furtherance of these strategies, the ACO REACH Model emphasizes provider and beneficiary support and input, with increased oversight to ensure compliance with the requirements and goals of the ACO REACH Model.
Application
CMS has indicated that the seven-week application window is the only opportunity for providers to participate in the ACO REACH Model for 2023. As such, all providers considering participation in the ACO REACH Model should apply during this window. Applications may be withdrawn at any time prior to signing a participation agreement.
Given the fast-approaching and relatively short application period, CMS is not requiring a Letter of Intent in order for a provider to submit an application. CMS has released the Request for Applications (“RFA”) that must be used when submitting an application for the ACO REACH Model.
Of note, any entity currently participating in the GPDC Model is not required to resubmit an application to participate in the ACO REACH Model. Instead, current participants of the GPDC Model will be allowed to continue in the ACO REACH Model so long as they have a strong history of compliance and agree to meet all ACO REACH requirements by January 1, 2023.
Key Deadlines
- March 7, 2022 – Application Period Opens
- April 22, 2022 – Application Period Closes
- August 1, 2022 – December 31, 2022 – Optional Implementation Period
- January 1, 2023 – First Performance Year Begins
Practical Takeaways and Next Steps
- The ACO REACH Model replaces the GPDC Model effective January 1, 2023.
- CMS is also eliminating the Geographic Direct Contracting Model.
- Any entities interested in participating in the ACO REACH Model should submit an application. Submission of an application is not an irrevocable commitment to participate in the ACO REACH Model.
- Entities that already participate in the GPDC Model are not required to resubmit an application to transition to the ACO REACH Model. These entities must have a strong compliance record and agree to comply with the ACO REACH Model requirements in order to continue in the program.
- Applications must be submitted by April 22, 2022.
- All participants must be in compliance with the ACO REACH Model requirements by January 1, 2023.
Hall Render will continue to monitor the ACO REACH Model closely as it develops and will issue additional information over the next few weeks. If you have any questions or would like additional information on this topic, please contact:
- Brian Bauer at (248) 457-7821 or bbauer@wp.hallrender.com;
- Amy Mackin at (919) 447-4963 or amackin@wp.hallrender.com;
- Jennifer Skeels at (317) 977-1497 or jskeels@wp.hallrender.com;
- Laetitia Cheltenham at (919) 447-4968 or lcheltenham@wp.hallrender.com;
- Megan Culp at (317) 429-3644 or mculp@wp.hallrender.com;
- Jennifer Struck at (317) 429-3674 or jstruck@wp.hallrender.com; or
- Or your regular Hall Render attorney.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
