NAACOS Newsletter for Members and Partners April 20, 2023

Table of Contents

NAACOS ADVOCACY

NAACOS to Co-Host Congressional Briefing
Read Our Blog on Including Primary Care Capitation in MSSP
Share Your Questions for CMS Officials at Our Conference
New Member Resource: ACOs and the Expiring COVID-19 PHE
Join Us for the Next ACO REACH Learning Discussion

CONGRESSIONAL UPDATES

Lawmakers Return to Washington with Spending Fights on Horizon

ADMINISTRATION UPDATES

CMS Releases Proposed and Final Rules
Updated MSSP Application Materials Released
Share Your Top HIT Needs
NAACOS Comments to PTAC on Engaging Specialists in ACOs
BPCI-A Deadline to Submit Data Extended
MSSP Beneficiary Notification Guidance Available

EDUCATIONAL EVENTS

Summer 2023 Boot Camp Registration is Now Open!
Still Time to Register for the Spring 2023 Conference
Did You Miss Any NAACOS Discovery Calls?
SNF 3-Day Waiver Post-Pandemic Reboot

MEMBER RESOURCES

Opportunities for ACO Conveners in BPCI-Advanced

WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE


NAACOS ADVOCACY


NAACOS TO CO-HOST CONGRESSIONAL BRIEFING
The House Health Care Innovation Caucus, in conjunction with the Alliance Value-Based Patient Care, is hosting a value-based care briefing for congressional staff on April 27. Reps. Mike Kelly (R-PA) and Ami Bera (D-CA), the co-chairs of the caucus, will be kicking off the briefing that will be held in the U.S. Capitol. The briefing will educate staff on how value-based health care is improving patient care, strengthening the delivery system, increasing flexibility for providers, and lowering costs. A recording will be available following the event. Please reach out to Robert Daley if you would like more information about how to invite staff from your congressional delegation to attend the briefing.

READ OUR BLOG ON INCLUDING PRIMARY CARE CAPITATION IN MSSP
There is broad multi-stakeholder support for CMS to implement a hybrid primary care payment model option within the Medicare Shared Savings Program (MSSP) to strengthen the primary care platform and drive accountable care. Our latest blog by NAACOS and alliance partner Primary Care Collaborative outlines approaches for how this option should be implemented. If you have suggestions for issues to highlight in our blog, please reach out to [email protected].

SHARE YOUR QUESTIONS FOR CMS OFFICIALS AT OUR CONFERENCE
CMS officials, such as John Pilotte, Director of the Performance Based Policy Group, Pauline Lapin, Director of the Seamless Care Models Group at the Innovation Center, and Molly MacHarris with the Center for Clinical Standards and Quality, will take the stage for our Town Hall session on May 5 at 1:15 pm. This session is a great opportunity for members to hear directly from CMS officials on your most critical ACO policy and operations issues. Share your questions with us in advance by emailing [email protected].


NEW MEMBER RESOURCE: ACOS AND THE EXPIRING COVID-19 PHE
NAACOS published a new fact sheet to help ACOs navigate the expiring COVID-19 Public Health Emergency (PHE). The PHE ending will impact quality reporting, telehealth, and mitigating shared losses for ACOs.

JOIN US FOR THE NEXT ACO REACH LEARNING DISCUSSION
NAACOS’ next ACO REACH Learning Discussion will take place April 21 from 12:00–1:00 pm ET. This month will focus on managing concurrent participation with other alternative payment models (APMs). Participation is limited to those participating in ACO REACH, and advanced registration is required. If you have questions or additional topics you want discussed, please share them in advance by emailing [email protected].

CONGRESSIONAL UPDATES

LAWMAKERS RETURN TO WASHINGTON WITH SPENDING FIGHTS ON HORIZON
The House and Senate return this week to continue discussions about increasing the debt ceiling and how to prioritize government spending. Congressional leaders are expected to call for votes in the coming weeks on bills to increase the debt ceiling and reduce government spending, although there is not yet consensus between Republicans and Democrats on how to move forward given disagreements over spending cuts. In the meantime, congressional committees will continue holding health care related hearings. The House Energy and Commerce will kick off a hearing this week where lawmakers will discuss the health workforce shortage and how to bolster the primary care system. Additionally, a bipartisan group of doctors in Congress introduced legislation to provide an annual Medicare physician payment updated tied to inflation.

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ADMINISTRATION UPDATES

CMS RELEASES PROPOSED AND FINAL RULES
  • Medicare Advantage. CMS finalized a final rule making several policy changes to Medicare Advantage plans, including those related to Star Ratings, marketing and communications, health equity, prior authorization, and other programmatic areas. CMS is altering requirements for plan marketing that aim to serve as beneficiary protections. CMS will also add a health equity index starting in 2027. The press release , fact sheet, and final rule are all available on CMS’s website. NAACOS is still analyzing a separate regulation from CMS that deals with risk adjustment and will share additional information on impact to ACOs later.
  • Inpatient Hospital. On April 10, CMS released the hospital inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment system proposed rule. Comments are due by June 9. A CMS fact sheet is available, proposed changes include:
    • Increasing payments to hospitals by 2.8 percent
    • Continuing add-on payments for COVID-19 treatments through September 30.
    • Adding new health equity adjustment to the Hospital Value Based Purchasing Program and changing the severity level for several social determinant of health diagnosis codes.
    • Modifying the promoting interoperability program and inpatient quality reporting programs.
  • Skilled Nursing. On April 4, CMS released a proposed rule to update payment rates and policies for skilled nursing facilities (SNFs). Comments are due by June 5. A CMS fact sheet is available, proposed changes include:
    • An estimated net payment increases of 3.7 percent.
    • Adoption of four new quality measures and a health equity adjustment for facilities with at least 20 percent of residents with a dual eligibility status.
    • Continued review of comments regarding minimum staffing requirements.
UPDATED MSSP APPLICATION MATERIALS RELEASED
CMS recently published details on the annual MSSP application cycle. The application toolkit now includes guidance on applying for advance investment payments (AIPs). Sample applications are also available for initial applicants, AIP supplemental information, renewing applicants, SNF 3-day rule waiver applicants, and beneficiary incentive program applicants. The application window is open from May 18 – June 15, 2023, at 12:00 pm ET for the January 1, 2024, start date. More information on application steps and timeline is available. NAACOS will be hosting a webinar on application details on May 25; registration will open soon.

SHARE YOUR TOP HIT NEEDS
NAACOS will be establishing a small working group to discuss Health Information Technology (HIT) issues and priorities for ACOs. We want to hear from members about the top HIT issues and priorities you are facing outside the transition to electronic clinical quality measures (eCQMs). Share with us by emailing [email protected].

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NAACOS COMMENTS TO PTAC ON ENGAGING SPECIALISTS IN ACOS
NAACOS recently submitted comments to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) on how ACOs can be better supported to further engagement with specialists in total cost of care models. This call for comments followed a public meeting PTAC held on the topic. In the letter, NAACOS urged CMS to share data on cost and quality performance for specialists with ACOs, support ACOs with shadow or nested bundled payments for those who elect these arrangements, and address policy and program design elements that currently are prohibitive to this work. PTAC is accepting comments on this topic until May 5, 2023; to submit email your feedback to [email protected].

BPCI-A DEADLINE TO SUBMIT DATA EXTENDED
In response to stakeholder feedback, CMS is extending the period for data review for Bundled Payments for Care Improvement-Advanced (BPCI-A) applicants to at least eight weeks after distribution of baseline data and preliminary targets. Applicants will receive baseline data and target prices in September 2023 and will be required to submit a signed model year seven participation agreement and a completed participant profile by December 4, 2023. An updated application process timeline for 2023 is available.

MSSP BENEFICIARY NOTIFICATION GUIDANCE AVAILABLE
CMS has published new guidance documents on the MSSP beneficiary notification requirements. The detailed guidance and FAQs include information about changes to the requirements that went into effect January 1, 2023. Importantly, the guidance documents fail to address several known issues with the requirements, including what information must be included in the follow-up communication and whether the follow-up can be packaged in the same communication as the standard beneficiary notice. NAACOS will continue to follow up with CMS to get answers to these questions and others. If there are additional issues you would like to raise on the beneficiary notification requirements, or if you have examples of challenges with implementing the current requirements, please share them to [email protected].

Compliance Manual

EDUCATION OPPORTUNITIES

SUMMER 2023 BOOT CAMP REGISTRATION IS NOW OPEN!
Mark your calendars for June 15-16 at the Denver Airport Marriott at Gateway Park for the Summer 2023 Boot Camp. Summer boot camp will provide information on data and analytics for new and advanced ACOs. This boot camp will meet the educational needs of ACO leadership and staff, including those responsible for building and overseeing data, analytics, and ACO financial interest. Boot camp topics have been announced with the full agenda to be released in the coming weeks.

Register NOW!

**This boot camp will only be offered for in person. There will be no virtual option. Boot camps are not open to business partners. Space is limited to 100 people.**

STILL TIME TO REGISTER FOR THE SPRING 2023 CONFERENCE
Join us May 3–5, 2023, for the NAACOS Spring Conference at the Hilton Baltimore Inner Harbor to hear directly from CMS officials who shape ACO and value-based care policy and operations. In addition, this two-day, in-person event will feature 16 breakout sessions with actionable knowledge for new ACOs joining the MSSP and REACH models, rural ACOs, independent primary care ACOs, and experienced ACOs in all models. See the full Agenda

REGISTER NOW! Registration for the in person and virtual conference will remain open until the conference begins.

**GROUP RATES** Take advantage of our group rates! We are offering group rates for both the in-person and virtual conference. To register at the group rate, please contact Emily Perron.

Sponsor opportunities and booth only options are still available! Contact Emily Perron for more information.

DID YOU MISS A NAACOS DISCOVERY CALLS?
If you wanted to join a previous discovery call but your schedule didn’t permit, you can now access them on the NAACOS Discovery Call page. These recordings cover topics discussed from November 2021 to now. These topics include Paramedic ROI, Specialist Engagement, Physician Compensation Learning Discussion, HCC Gap, End of Life, Epic Claims Ingestion, Beneficiary Notification, and Arcadia Users. All of these topic discussions were organized due to significant interest on the NAACOS listserv. If you have questions on a specific topic and wonder how other ACOs are approaching it, you can post a message to the listserv at any time once you have requested access at the ListServ sign-up page.

SNF 3-DAY WAIVER POST-PANDEMIC REBOOT
Is your ACO new to the SNF 3-Day Waiver or do you need to reboot your program with PHE declaration rules ending on May 11? If so, our webinar on May 17 at 2:00 pm ET will provide information on how others are completing this challenge. The webinar will feature Cindy Yeager, Care Gaps and Quality Data Manager for Keystone ACO, who will provide an overview of the SNF 3-day waiver program, re-education planning, and implementation to assure compliance under their MSSP contract once the PHE declaration ends. If you are a post-acute placement program manager or staff, this webinar is for you! Register now!

MEMBER RESOURCES

OPPORTUNITIES FOR ACO CONVENERS IN BPCI-ADVANCED
CMMI has extended its bundled payment program through 2025 and created a new pathway for ACOs to join as convener organizations. As a convenor, an ACO can partner selectively with its own members as well as with non-ACO hospitals and provider groups under gainsharing arrangements.

Since BPCI-A rewards improvement, one ACO convener strategy for success is to partner with less efficient hospitals and physicians that have potential to improve.

NAACOS/IAC can help you identify potential partner institutions and clinical episodes with high potential for improvement. Contact us to learn how episode spending data and our benchmark reports can inform your ACO strategy.

WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE
  • The Medicare Payment Advisory Commission (MedPAC) held public meetings last week where commissioners suggested that Congress hold off on making any final decisions about permanently expanding access to telehealth. The next report with recommendations to Congress will be released in June.
  • The Commonwealth Fund published an issue brief on the work of Medicaid ACOs.