Though all years have their share of natural disasters, 2017 stood out as one of the more turbulent years in recent memory. Between wildfires sweeping across California and three major hurricanes–Harvey, Irma, and Maria–devastating the U.S. and Caribbean in just over the course of a month, this past year has brought destruction to both sides of the country. Thankfully, in the midst of such catastrophes, the Centers for Medicare and Medicaid Services (CMS) have adjusted some of their policies to reflect the uncontrollable circumstances caused by these disasters.
On December 21st, 2017, CMS formally announced that the Extreme and Uncontrollable Circumstances Policies for the 2017 performance year would be updated to align with Medicare Shared Savings Program accountable care organizations (facilities in which providers are jointly accountable for patients and subsequently receive financial incentives for avoiding duplicate or unnecessary services). In other words, the Shared Savings Program reported by these accountable care organizations, or ACOs, will be judged differently in order to reflect the hardships they had to endure during these natural disasters. Such criteria will go into effect in all future incidents, but will also be retroactively applied to specific disasters from the past year. These new regulations begin on January 20th, 2018, but CMS will allow comments and suggestions regarding the rule up until February 20th.
According to the Federal Register, CMS “believe[s] it is also appropriate to establish automatic extreme and uncontrollable circumstances policies under the Shared Savings Program for performance year 2017 due to the urgency of providing relief to Shared Savings Program ACOs impacted by Hurricanes Harvey, Irma, and Maria, and the California wildfires, because their quality scores could be adversely affected by these disasters and some ACOs could be at risk for additional shared losses due to the costs associated with these extreme and uncontrollable events.”
If you work for an affected ACO, be sure to review the full proposal in order to prepare your workplace for submitting the proper Shared Savings Program criteria, both now and in the years to come.