Patients are assigned to the ACO and assignment or “attribution” is tied to the TIN/NPI combo. If that TIN/NPI is no longer billing, leaves, and isn’t submitted in the provider list next year, the practice will lose those patients, unless another NPI under the practice’s TIN sees them during that same Performance Year, in which case CMS will likely realign the patients.

In the event a provider in your practice leaves, the practice is still at risk for managing those patients. However, you can retain those lives by transitioning them to management under a provider still existing in the practice by having the patient sign a voluntary alignment form. You will continue to receive PBPM for those patients until the end of the performance year, but risk losing them to claims alignment with their former provider unless they voluntarily align with another provider in your practice.