NAACOS Newsletter for Members and Partners February 10, 2022

Table of Contents
Register for Upcoming Health Equity Webinar
Spring Conference Agenda Now Available
Congressional Lawmakers Embrace Short Term, Middle Ground
Ask Your Congressional Representatives to Support ACOs
Next DC Learning Discussion Scheduled for February 18
Questions about How and When to Take on More Risk?
NAACOS Releases Updated ACO Comparison Chart
CMS Releases 2023 MA and Part D Advance Notice
NAACOS and Others Ask Congress to Strengthen APM Incentives
Senators Discuss ACOs During Congressional Hearing
Snapshot of 2021 QP Status and APM Participation Data Posted
NAACOS Joins Over 50 Organizations on Letter to Senate Committee
CMS Releases Preliminary 2020 QPP Results
NAACOS Supports CMS’s Proposed Limited Coverage of Aduhelm
Quality Reporting Deadline is March 31

REGISTER FOR UPCOMING HEALTH EQUITY WEBINAR
NAACOS invites everyone interested in health equity to join us for an exciting webinar we have planned for February 15 at 11:00 am ET. This webinar is part of ongoing work by NAACOS to engage in conversations around health equity and explore how alternative payment models can facilitate health equity initiatives. While there are significant barriers to addressing health inequities, many ACOs are undertaking a range of efforts to close health equity gaps and meet patients’ nonmedical needs in order to improve their health and well-being. In this webinar, titled How ACOs Are Addressing Health Equity: Insights from Innovators, we will explore addressing and improving equity in value-based care. Speakers from Advocate Aurora Health, Aledade, and Mount Sinai Health System will highlight how the ACO model can be leveraged to address health equity, sharing challenges and lessons learned through the planning and implementation of equity-focused initiatives. Members and partners are free, all others are charged $195. Register now!
Welcome New Business Partners
Community Infusion Solutions
CIS increases a hospital’s market share of infusion services, reduces outmigration by developing disruption strategies, increases referrals from large regional providers by ensuring patient compliance and reducing re-admittance rates, and provides data-driven strategies to address the needs of individual hospitals.
communityiv.com
Healthmap Solutions
Healthmap Solutions has a rich history forged in data and analytics. Today, we use our advanced technology, superior clinical expertise, and complex care management know-how to power a Kidney Health Management (KHM) program that delivers improved care, outcomes, patient experience, all while driving savings.
healthmapsolutions.com
BrainCheck
The BrainCheck Platform provides tools for rapid cognitive assessment and clinical decision support, cognitive care management and a digital therapeutic.
braincheck.com
BrightStar Care
BrightStar Care nurses, therapists, CNAs, and caregivers deliver professional and compassionate care in the comfort and familiarity of home. We are proud to provide the full range of home care services to meet someone’s unique needs. From companionship and personal care, to infusion therapy, medication management, senior care and Alzheimer’s care, our professional care staff is available 24/7 to help when you need it most.
brightstarcare.com
SPRING CONFERENCE AGENDA NOW AVAILABLE
Join us on April 27–29 at the Hilton Baltimore Inner Harbor and hear from leading value-based care experts and CMS officials sharing timely and essential information for ACOs and other alternative payment models. A detailed agenda is now posted and will feature breakout sessions on:
  • Critical Policy Update for ACOs and DCEs
  • Increasing Health Equity
  • Quality Management Across Contracts
  • Using Data in Benchmarking
  • Clinical Transformation Through Data
  • Annual Wellness Visits
  • Using Episodes of Care to Evaluate Specialist Performance
  • Digital Care Including Remote Monitoring
  • Understanding Direct Contracting Compliance and Operations
  • Effective Contracting Strategies with SNFs
The conference will also include our peer-to-peer exchanges, quality award winners, and the popular CMS Townhall to close out the conference.

Two pre-conference workshops* on April 27 from 1:00 to 5:00 pm can enrich your conference learning with actionable strategies for your ACO’s success. The two workshops will be:
  • Expedite the Learning Curve for Success in Medicare Advantage led by Kim Kauffman
  • Conundrums in Care: Innovative Post-Acute Strategies led by Jessica Martensen, Essentia Health
*These workshops require separate registration from the main meeting.

Register Early and Save
Register before March 4 for the in-person conference and receive a discount of $300 per person. Can’t attend in person? Register for our live webcast before March 4 and receive a discount of $100 per person. Proof of vaccination required to attend in-person.

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. Group rates are only available to NAACOS member ACOs and DCEs. If your organization is not a member, join now and save!


CONGRESSIONAL LAWMAKERS EMBRACE SHORT TERM, MIDDLE GROUND
Democratic Senator Ben Ray Lujan (D-NM) suffered a stroke last week, effectively decreasing the Senate majority from a 50–50 Senate (with a majority vote from Vice President Kamala Harris) to a 50–49 Senate. Lujan’s absence, combined with periodic illnesses on both sides of the aisle due to COVID-19, complicates the Senate Majority’s ability to move controversial legislation and/or President Biden’s political appointees and is likely to put the already stalled Build Back Better agenda on the back burner for the next several weeks. At the same time, some bipartisan efforts, including election reform and limitations around required pre-trial arbitration for sexual assault, are highlighting the effectiveness of bipartisan work on issues, at least in the slim-majority Senate. Like the bipartisan passage of the infrastructure funding bill earlier in President Biden’s term, the successful advancement of several bipartisan policies has undermined partisan strategies.

This week, the House is likely to pass a short-term funding bill after negotiations among appropriators failed over the weekend. Funding for the federal government is set to expire on February 18, and it is anticipated that Congress will pass a 30-day continuing resolution (CR) to stave the budget expiration. After the House passes its measure, a CR would also require Senate passage, likely to occur late this week or early next. At the same time, Congress is continuing its work on the America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (COMPETES) Act of 2022 (House version), or U.S. Innovation and Competition Act (Senate version), which includes some provisions on information technology, digital health, and research of interest to healthcare stakeholders—that measure passed out of the House last week and the Democratic Majority will seek to reconcile the House and Senate versions. This Thursday, the Senate Health, Education, Labor and Pensions (HELP) Committee will meet for a hearing on healthcare workforce issues after numerous organizations have pushed over the last several weeks to highlight clinician and administrative worker shortages in health centers nationwide. The House Energy and Commerce Committee will also meet for a hearing on Tuesday regarding the creation of an Advanced Research Projects Agency for Health (ARPA-H) to fund research for innovative healthcare technologies and therapies.


ASK YOUR CONGRESSIONAL REPRESENTATIVES TO SUPPORT ACOS
Several members of the House of Representatives are sending a letter with colleagues asking the Biden administration to adopt common-sense policies to increase ACO participation. NAACOS is asking our members to write their elected officials today encouraging them to join the letter! To achieve the goal of having every Medicare beneficiary in an accountable care model by 2030, CMS and the Innovation Center must work to grow provider participation in ACOs and other alternative payment models (APMs). NAACOS feels the recommendations in this letter would do that, and we appreciate the Innovation Caucus’s leadership on drawing attention to these important issues.

NEXT DC LEARNING DISCUSSION SCHEDULED FOR FEBRUARY 18
NAACOS is holding its next Direct Contracting (DC) Learning Discussion on February 18. As a reminder, these monthly events are meant for direct contracting entities (DCEs) to share feedback, questions, concerns, and points of interest. Participation is limited to those participating in the model in 2022, and as such, advanced registration is required.

If you have questions or topics of conversation you want discussed, please share them in advance by emailing us. The point is to make these collaborative discussions and a forum for shared learning. We ask that you come prepared to share your questions and perspectives and to react to issues at hand.


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QUESTIONS ABOUT HOW AND WHEN TO TAKE ON MORE RISK?
It will soon be application season and many ACOs who are working on the risk strategy and trajectory of their ACO for 2023 may be questioning how to best approach taking on more risk. NAACOS will hold a webinar on February 22 at 2:00 pm titled Navigating through Shared Risk Contracting to provide insight and tips for this process. This webinar will discuss why taking on risk could be the best move for your providers to support the transition from fee-for-service to value-base payments through the utilization of CMS programs. Content will include how to navigate the Medicare Shared Savings Program (MSSP) program to increase risk to the highest risk enhanced track and beyond, how to get involved and play a role in the transition to increased risk, and what the benefits can be to your organizations and practices. Session presenters will include Shawn Bassett, VP Program Operations, and Jim Piccillo, VP of Business Development form Collaborative Health Systems. The webinar is free for members and business partners and $195 for non-members.

NAACOS RELEASES UPDATED ACO COMPARISON CHART
Recently, NAACOS published an updated edition of the MSSP ACO Comparison Chart. This helpful resource details key program elements and highlights similarities and differences between the current participation track options in MSSP. The chart examines general track details, financial policies, quality reporting, and compliance and waiver policies, reflecting policies in place for Performance Year (PY) 2022. Importantly, this edition of the chart includes key changes to quality reporting requirements that were finalized in the Final 2022 Medicare Physician Fee Schedule. More details about the new quality requirements are available.

CMS RELEASES 2023 MA AND PART D ADVANCE NOTICE
CMS is proposing to increase payments to Medicare Advantage (MA) plans by an average of nearly 8 percent in 2023. That includes a 4.75 percent growth rate and average risk score increase of 3.5 percent before normalization. By comparison, MA plans received an average payment increase of about 4 percent in 2022. MA continues to receive huge amounts of bipartisan support, as evinced by a recent letter signed by 346 members of Congress or roughly 80 percent of the chamber, which is translating into generous payment rate increases. Comments are due by March 4 with an expected final regulation by April 4. The fact sheet and advance notice are published online.

Of interest, CMS says it is considering a new measure to capture value-based care arrangements that MA plans have with providers, including risk sharing, bonuses or penalties based on meeting performance targets, and non-financial resources to drive outcomes and lower costs. CMS also solicits feedback on the effects of patients’ social determinants of health on risk scores. Lastly, CMS is considering the development of a Health Equity Index to potentially change Star Ratings to better take into account how plans advance health equity. Potential measures include how often plans are screening for common health-related social needs, such as food insecurity, housing insecurity, and transportation problems.

In 2023, CMS proposes to apply a 5.9 percent coding pattern adjustment, which is the minimum adjustment required by statue. While CMS typically normalizes risk scores to better average risk scores’ increases, CMS is not basing 2023’s normalization factor on 2021 risk scores, which is based on dates of service from 2020, because of concerns around the COVID-19 pandemic.



NAACOS AND OTHERS CALL ON CONGRESS TO STRENGTHEN APM INCENTIVES
NAACOS and other leading value-based care stakeholders urged Congress to do more to encourage the adoption of APMs in Medicare to improve patient care and prolong the Medicare Trust Fund. In a statement for the record provided to the Senate Finance Committee on its recent hearing, further described in the article below, regarding the Hospital Insurance Trust Fund and the Future of Medicare Financing, the groups point to evidence that ACOs improve quality and patient outcomes while having successfully lowered the rate of spending growth in Medicare. The statement also calls on Congress to extend the Advanced APM bonus for an additional six years and give the HHS Secretary greater discretion to determine thresholds providers must reach to receive those bonuses. These bonuses have been instrumental in encouraging participation in risk-based APMs, but 2022 is the last performance year in which ACOs and other Advanced APM participants can qualify to earn the bonus. NAACOS is working hard to advocate that Congress extend these bonuses and encourage more providers to enter into ACOs and APMs that have proven to provide Medicare patients with better quality care at lower costs.

SENATORS DISCUSS ACOS DURING CONGRESSIONAL HEARING ON MEDICARE TRUST FUND
During a Senate Finance Committee hearing last week on the Medicare Trust Fund, Senator Sheldon Whitehouse (D-RI) spoke about how ACOs are leading the Medicare value-based care transformation, resulting in better quality care and saving the Medicare program money. Senator Whitehouse has been a champion of ACOs since the program’s inception nearly 10 years ago. He reaffirmed his support during the hearing and called on his senate colleagues to come together to further strengthen the program and increase participation. NAACOS looks forward to working with Senator Whitehouse and members of the committee to continue improving Medicare’s accountable care programs. Senator Elizabeth Warren (D-MA) also called on the Biden administration to end the Direct Contracting Model, claiming it would privatize Medicare. NAACOS disagrees with her comments, supports the model, and is reaching out to her office to discuss her concerns.

SNAPSHOT OF 2021 QP STATUS AND APM PARTICIPATION DATA NOW POSTED
CMS recently updated the Quality Payment Program (QPP) participation status tool to reflect the third PY 2021 evaluation for meeting Advanced APM thresholds, known as Qualifying APM Participant (QP) thresholds. This third snapshot period covers January 1 through August 31, 2021. This is the second QP evaluation for DCEs, which covers April through August 31, 2021. QP providers must receive at least 50 percent of their Medicare Part B payments or see at least 35 percent of Medicare patients through an Advanced APM entity to be eligible for a 5 percent bonus paid in 2023.

As previously reported in our November newsletter, more providers in ACOs and DCEs will be eligible to earn these bonuses as a result of NAACOS’ advocacy to prevent the QP thresholds from sharply rising in 2021. To learn more about these bonuses, QP thresholds, and how to qualify, please refer to NAACOS’ resource, The ACO Guide to MACRA.


NAACOS JOINS OVER 50 ORGANIZATIONS ON LETTER TO SENATE COMMITTEE
Last week, NAACOS signed onto a letter with more than 50 other organizations, which was sent to the Senate HELP Committee requesting that the committee include key social determinants of health (SDOH) provisions in the recently-proposed Prepare for and Respond to Existing Viruses, Emerging New Threats, and Pandemics Act (PREVENT Pandemics Act). The letter, led by Aligning for Health, suggests that the full text of the bipartisan Leveraging Integrated Networks in Communities (LINC) to Address Social Needs Act (S. 509/H.R. 6072) should be included in the legislation. NAACOS endorsed the LINC to Address Social Needs Act when it was introduced in the Senate and the House during 2021. This bill would support cross-sector efforts to coordinate and address health-related social needs by providing funding to build or enhance sustainable closed-loop referral networks in order to coordinate effectively between physical and behavioral health care and social services and community-based organizations.

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CMS RELEASES PRELIMINARY 2020 QPP RESULTS
CMS recently published preliminary results for QPP PY 2020. Important trends include a 21.3 percent increase in the number of Qualifying APM Participants (QPs) from 2019 to 2020, with 25.4 percent of Merit-Based Incentive Payment System (MIPS) Eligible Clinicians meeting QP status for 2020. This is the highest number of QPs since the start of the program. Those clinicians who met QP status for 2020 will be awarded a 5 percent Advanced APM bonus payment in payment year 2022. Under current interpretation of the Advanced APM bonus payment program, the bonus is only earnable through December 31, 2022. NAACOS is advocating that Congress act expediently to extend the Advanced APM bonus in order to ensure continued growth in Advanced APM participation. NAACOS has drafted an editable letter so that you can write your member of Congress today to urge them to support this extension!

Additionally, participation in MIPS APMs decreased by approximately 4.2 percent for a total of 398,719 participants in 2020. We also see an increase in final MIPS scores, with the average score reaching 89.41 and a median score of 96.82. Please note this refers to final overall MIPS scores, not the MIPS quality performance category scores that MSSP ACOs are compared with under the new quality performance threshold. More information on the recent changes to quality reporting and scoring for MSSP is available. It is important to note, these preliminary results are based on data that has not yet undergone targeted reviews, and the final participation results will be available in the coming months. If you have specific questions for the QPP, you can email [email protected].


NAACOS SUPPORTS CMS’S PROPOSED LIMITED COVERAGE OF ADUHELM
NAACOS in a letter submitted this week urged CMS to finalize its proposed National Coverage Determination (NCD) for monoclonal antibodies that target amyloid for the treatment of Alzheimer’s disease. A proposed NCD published on January 11 would cover Aduhelm (aducanumab), the first FDA-approved drug to treat Alzheimer’s Disease in more than 20 years for people with Medicare only if they are enrolled in qualifying clinical trials. Expressing concerns that the expected costs of Aduhelm, which was approved on June 7, would outweigh its clinical benefits, NAACOS was supportive of the narrow proposed NCD until more scientific evaluations exist to support the drug’s efficacy. The list price of $28,000 per person for a year of treatment is nearly two-and-a-half times the average ACO’s benchmark. While not necessarily part of CMS’s work on an NCD, NAACOS also urged CMS to adjust ACO benchmarks to mitigate Aduhelm’s cost.

2021 QUALITY REPORTING DUE MARCH 31
The MSSP quality submission process for PY 2021 will close on March 31, 2022. As a reminder, 2021 is the first year the APM Performance Pathway (APP) scoring rules apply to all MSSP ACOs. Under the new APP structure, for PY 2021, MSSP ACOs can choose to report either 10 Web Interface measures or three electronic clinical quality measures (eCQMs) or MIPS CQMs (supported by a registry). Reporting will take place via the QPP website. CMS advises ACOs to ensure they have the necessary Health Care Quality Information System Access Roles and Profile (HARP) accounts. ACOs can manage their HARP user roles in the ACO Management System (ACO-MS). This includes ensuring the ACO has a QPP Security Official listed in the ACO-MS. CMS has provided tip sheets and user guides to assist with this process, available in the ACO-MS. Access our new resource to learn more about your ACO’s quality reporting options for 2021 through 2025, as well as important changes to quality scoring that can have significant impact on your ACO and your shared savings.