MACRA is actually at least as risky as MSSP - and deserves resources to manage the risk.  

For 2019, MACRA sets penalty for non-performance at 7% of Part B Payments to providers.  Under the Basic Glide Path, losses are limited to 4% of Benchmark, or 8% of combined Part A and Part B revenues.  

Since MACRA is calculated against just Part B revenues, an adjustment is necessary for apples-to-apples comparison. If we assume that across broad populations, Part B makes up about 50% of total health care dollars, then doubling the ACO (Part A + B) loss rate would approximate a physician (Part B only) rate.  

With this logic, an ACO under Glide Path D (which caps losses at 2% of Benchmark or 4% of Revenues) would achieve a maximum loss of between 4% - 8% of Part B revenues.  With 2019 MACRA negative adjustments of -7% for 2019, and -9% for following years, MACRA falls squarely in the same range as ACO level loss.  

Of course, there are a lot of variables impacting both MACRA, and ACO negative adjustments.  But contemplating the broad strokes, it seems that prudent ACO organizations should be making sure its providers receive sufficient MACRA care and attention to stay out of financial trouble.  Download our rough-cut model to validate this logic against your own assumptions!