As the Medicare ACO program enters its fourth year and Part D celebrates its ninth year, the Centers for Medicare & Medicaid Services is investigating ways to marry the two programs to bring coordinated care and the concept of shared savings to Medicare drug benefits.

It's a tricky equation, as Medicare ACO payment models have not directly targeted prescription drugs and Part D is outside of the shared budget calculation used by CMS. But the federal agency is trawling the industry for innovative suggestions.

Questions include what factors pose barriers to effective collaborations? Are ACOs prepared to accept insurance risk, either as Part D sponsors or through contracting with pharmacy benefit managers? Do ACOs currently have access to enough data to accept full risk for Part D expenditures?

This has been an ongoing search for CMS. The agency sought industry input on Part D ACOs through a request for information in December 2013, and asked again in October 2014 how value-based programs can work for Medicare Advantage and Part D. In October, CMS officials were at the annual Medicare/Medicaid conference hosted by America's Health Insurance Plans in Washington, D.C., praising the progress made by Part D plans and ACOs. For their part, ACOs produced savings of more than $380 million during the first year of the Medicare Shared Savings Program and Pioneers program. Part D is expected to grow to 53 million lives by 2018, up from the current figure of 41 million.

Before the ACO concept can be applied to Part D benefits, there are issues that need to be ironed out. As my HealthLeaders-InterStudy colleague Jane DuBose pointed out in her Sept. 25 blog, results for Medicare Shared Savings ACOs have been mixed at best, as only one in four saved enough money on patient care in year one to share in savings with the federal government.

Nevertheless, the intentions are clear that CMS intends to move forward with testing the model with Part D plans. While PDP sponsors have demonstrated some success in promoting medication adherence and improving drug therapy management, the agency says it's interested in learning whether additional flexibility could further control costs. Already under consideration is a PDP model that will test the impact of robust medication therapy management programs that effectively target Part D beneficiaries and better coordinate care.

CMS has actively been linking fee-for-service payments for value while shifting towards population management models. Testing ACOs with MA-PD and standalone plans fits with this progression. Despite mixed results on the performance of ACOs thus far CMS continues to move forward advancing alternative strategies to fee for service.

Follow Chris Silva on Twitter @ChrisSilvaDRG

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