Q&A: Fulfilling ACO performance year requirements

Q: What activities are required of an accountable care organization (ACO) during performance years?

A: During the agreement period, ACOs engage in various activities during performance years, including coordination of care for beneficiaries, measuring and improving quality, and reporting the results back to CMS. Preparation for the next performance year occurs by ensuring the contact information in CMS’ system is current and completing the annual certification process. Participation in the SSP is contingent on ACOs completing this process prior to the start of the upcoming performance year. The ACOs must review official program documents, certify their compliance, and electronically sign the official program documents. They also receive financial and quality performance results at the end of each performance year.

During a performance year, ACOs must comply with several key requirements, including notifying Medicare FFS beneficiaries of its participation in the SSP by displaying a poster in each facility. This poster should be placed in key locations such as admitting, the emergency department waiting room, or the registration area. CMS provides ACOs with specific guidance on marketing the SSP affiliation to Medicare FFS beneficiaries upon completion of the application process.

Beneficiary assignment is a key factor calculating an ACO's financial benchmark and resulting success or failure to reach its goals at the close of each performance year. This data is also used in quality reporting. In addition to reporting its data, the ACO is also provided with information from CMS on
its assigned population and financial performance at the start of the agreement period and several times during the performance year.

ACOs' additional obligations during the performance year include maintaining a current electronic funds transfer authorization agreement (Form CMS-588) to receive shared savings. The organizations must also comply with program requirements, and have a designated compliance official and detailed compliance plan.

For more information, see The Essential Guide to Healthcare Payer Contracting.