Main Library
One of the biggest disconnects in Medicare value-based care is that the architecture of value-based programs run by the Centers for Medicare and Medicaid Services (CMS) has not caught up with how health systems actually bill.
More specifically, there’s a mismatch between the organizational unit CMS uses to administer accountable care and the way modern health systems organize billing. That mismatch appears in both the Medicare Shared Savings Program (MSSP) and the forthcoming Long-term Enhanced ACO Design (LEAD) Model. Although the programs use different alignment methodologies, both make the Medicare-enrolled taxpayer identification number (TIN), a foundational unit of participation and beneficiary accountability.
In the commercial insurance market, health systems are structurally encouraged by market dynamics to consolidate TINs: bigger, consolidated TINs can create negotiating leverage with commercial payers, simplify contracting, and help systems replicate the reality of a unified enterprise in the market.
A TIN is an administrative billing identifier, not necessarily a clinically coherent care-management unit. A single health-system TIN may encompass multiple primary care practices, longitudinal specialists, procedural specialists, hospital-based clinicians, and multiple sites of care.