The introduction of the Accountable Care Prospective Trend (ACPT) in the Medicare Shared Savings Program (MSSP) represents a major shift in how Accountable Care Organizations (ACOs) are benchmarked and incentivized. As a management company overseeing both prospective (REACH) and retrospective (MSSP) ACO models, Advanced Management USA is closely analyzing the implications of this change to ensure our partners remain strategically positioned for success.
The ACPT: A Step Toward Greater Predictability?
One of the longstanding challenges MSSP ACOs have faced is the uncertainty surrounding benchmark trends, which are only finalized after the performance year concludes. The ACPT, introduced in 2023 for 2024 agreement periods, aims to solve this by establishing fixed, prospective benchmarks at the start of the year.
This change is significant because it reduces financial uncertainty—ACOs can now plan budgets and operational strategies with a clearer picture of expected benchmarks. However, it also raises concerns about accuracy, as early projections may not always align with actual Medicare cost trends.
Predictability vs. Accuracy: The Balancing Act
While predictability is valuable for ACOs planning multi-year strategies, the accuracy of ACPT projections remains uncertain. The early data suggests a notable gap between projected and actual Medicare spending growth:
- CMS projected a 3.6% cost growth for 2024 using ACPT, yet recent data suggests actual trends may be closer to 9%.
- This means MSSP ACOs using ACPT may have lower benchmarks (about 2% lower on average) than under the previous methodology.
For MSSP ACOs, this discrepancy could create unexpected financial headwinds—potentially making it harder to generate shared savings in an environment where actual costs are rising faster than anticipated.
Implications for MSSP and REACH ACOs
At Advanced Management USA, we support both MSSP and ACO REACH models, each of which approaches benchmarking differently:
- MSSP ACOs (Retrospective Benchmarking): ACPT shifts MSSP benchmarks toward a more prospective methodology, which aligns more closely with how ACO REACH already functions.
- ACO REACH (Prospective Benchmarking): Unlike MSSP, REACH ACOs have always relied on fully prospective benchmarks, meaning they already navigate the challenges of forecasting future trends rather than relying on retrospective adjustments.
Given the growing shift toward prospective methodologies in Medicare ACO programs, it’s clear that CMS is increasingly favoring models that offer upfront financial clarity—even at the risk of misalignment with actual spending trends.
Key Strategies to Adapt to ACPT Benchmarking
For MSSP ACOs, understanding the risks and opportunities of ACPT is essential. Here’s how ACOs can proactively manage these changes:
1. Consider the Implications of Rebased Benchmarks
Since ACPT trends are locked in for five years, if actual costs outpace the projected trend, ACOs may face progressively tougher financial conditions. If trends continue to diverge, ACOs may want to evaluate whether rebasing in a new agreement period could offer more favorable benchmarks.
2. Monitor the Impact of CMS Guardrails
CMS has introduced guardrails to mitigate excessive losses under ACPT:
- If an ACO incurs losses under ACPT, CMS will recalculate financial settlements using the previous methodology.
- However, this only applies to shared losses, meaning ACOs won’t gain extra shared savings if actual trends are lower than ACPT assumptions.
3. Leverage Financial and Risk Management Strategies
Given the potential for misalignment between projected and actual trends, ACOs should consider strategies such as:
- Enhanced data analytics to track real-time cost trends
- Operational flexibility to adjust strategies based on performance indicators
- Risk diversification through participation in multiple ACO models (MSSP and REACH)
Final Thoughts: What’s Next for ACOs?
The shift toward more prospective benchmarking is part of a broader trend in Medicare’s value-based care evolution. While ACPT introduces greater predictability, it also forces MSSP ACOs to think more like REACH ACOs, where financial outcomes hinge on the accuracy of long-term projections.
At Advanced Management USA, we are committed to helping our partner ACOs—both MSSP and REACH—navigate these changes strategically. By leveraging our expertise in both models, we can develop tailored approaches that mitigate risk while maximizing opportunities for shared savings.
Want to discuss how ACPT will impact your ACO? Contact us today to learn more about our data-driven, strategic approach to ACO management.
References & Sources:
- Milliman Insight Article:
Predictability vs. Accuracy in MSSP Benchmarks: Understanding the Accountable Care Prospective Trend (ACPT)
Read the full article here - CMS Final Rule on ACPT Implementation:
Medicare Program; CY 2023 Physician Fee Schedule Final Rule (Published by CMS)
Read the final rule here - MSSP Benchmarking Methodology (CMS Official Page):
Medicare Shared Savings Program (MSSP) Fact Sheet & Regulations
Access the CMS MSSP resource here - ACO REACH Model Overview:
CMS Innovation Center: ACO Realizing Equity, Access, and Community Health (REACH) Model
Learn more about ACO REACH
