NAACOS Newsletter for Members and Partners January 13, 2022

Table of Contents
What to Watch in 2022
2022 Quality Measure Information Now Available
Congress Mulls Rule Changes While BBB Stalls
Register for NAACOS Health Care Value Week Webinar
NAACOS Resource on Medicare Payment Updates Under MACRA
January’s Direct Contracting Learning Discussion Now Scheduled
2021 Quality Reporting Underway
NAACOS Spring 2022 Conference Topics Announced
Send Your Submissions for Leaders in Quality Excellence
CMS Updates QPP Status Tool to Include Third 2021 Snapshot
CMS Publishes Proposed Changes to Medicare Advantage Plans
CMS Proposed Limited Coverage of New Alzheimer’s Drug
Kidney Care Choices Model Participants Announced
NAACOS' 2022 Boot Camp

WHAT TO WATCH IN 2022
The new year brings opportunities and challenges for ACOs and value-based care providers, despite lingering effects of the COVID-19 Public Health Emergency (PHE) and other common themes. The Biden administration will have a second year to implement its agenda, which includes expanding accountable care. Important issues confront Congress, which faces November elections and continued work on a large social spending package. NAACOS is poised to help members learn and adjust to an ever-changing landscape, and we have drafted the top issues for ACOs to watch in 2022. As always, we encourage members to contact us with any questions or concerns at [email protected].

NAACOS Resource Review:
Telehealth resources for 2022

As a new year begins, we want to remind our members of the resources available to provide guidance for the continued development of your telehealth programs. A summary of the updates in the Final Medicare Physician Fee Schedule (PFS) Rule for telehealth can be found on this CMS Fact Sheet. Additionally, there are resources for telehealth visit and billing requirements related to COVID-19 PHE flexibilities on the NAACOS Telehealth and COVID-19 page. This includes a link to the CMS Current Emergencies webpage containing numerous up-to-date links to the current PHE policies and toolkits. The CMS emergencies page contains a nursing home telehealth toolkit for long term care nursing homes visits, which has been a recent topic of interest among NAACOS member leading to a webinar on annual wellness visits.

2022 QUALITY MEASURE INFORMATION NOW AVAILABLE
CMS has released 2022 quality measure information. This includes both Web Interface and Merit-Based Incentive Payment System (MIPS) clinical quality measure information and supporting documents. In addition, the Quality Payment Program (QPP) resource library includes an alternative payment model (APM) Performance Pathway (APP) toolkit providing an overview of quality requirements for the APP. NAACOS has created a resource to outline key APP information for ACOs specifically, including quality requirements for ACOs in 2021 through 2025 under the new APP policies.

CONGRESS MULLS RULE CHANGES WHILE BBB STALLS
Negotiations concerning the Build Back Better (BBB) spending legislation have stalled following news that Sen. Joe Manchin (D-WV) will not support the package. In a further sign that the legislation is on the back burner for now, the Senate parliamentarian has ceased to continue its “Byrd Bath” review of the legislation, pending further developments. Provisions concerning drug pricing and other health related matters may advance later this year as more limited bills. This week Congress turns to voting rights legislation, including a push by the White House and Majority leadership to alter Senate rules—namely, the filibuster—to allow a vote on the matter. At the same time, pressure is increasing for House appropriators to act on government funding, and Democrat Appropriations leadership has scheduled a number of hearings this week to underscore the impact of federal funding on the federal government’s ability to respond to the ongoing coronavirus surge, defense, and national security matters. Lastly, Rep. Pramila Jayapal (D-WA), Chair of the Progressive Caucus, led a letter with more than 50 lawmakers calling for the Biden administration to cancel the Direct Contracting Model. NAACOS responded with a letter in support of the model and is engaged on this and other issues on Capitol Hill as we work to advance our priority items for 2022.
Welcome New Business Partners
Access Telehealth
Access Telehealth offers remote patient care programs that include innovative remote patient monitoring devices, software, and clinical monitoring services that can help practices, clinics, and health systems fully implement transformative chronic care and disease management programs.
accessrpm.com
REGISTER FOR NAACOS’S HEALTH CARE VALUE WEEK WEBINAR
NAACOS invites all members and business partners to tune into an exciting webinar we have planned for January 25 in conjunction with Health Care Value Week. This is a weeklong series of virtual events meant to raise awareness to issues facing value-based care, including polices needed to advance their work. Registration is free for all events, and we encourage NAACOS members to attend.

The NAACOS-sponsored event, entitled How ACOs Improve Patient Outcomes: Lessons Learned After a Decade of Clinical Transformation, will examine the care-improvement processes and clinical practices that have been employed by three of the most successful ACOs. Speakers from Privia Health, Advocate Aurora Health, and Baylor Scott & White Quality Alliance will share how they work to improve quality while lowering cost of care over time. Register now!


NAACOS RESOURCE ON MEDICARE PAYMENT UPDATES UNDER MACRA
This week, NAACOS published a new resource outlining Medicare payment updates under the Medicare and CHIP Reauthorization Act of 2015 (MACRA) for Performance Years (PY) 2017 through 2024. Importantly, this document highlights the expiration of the 5 percent advanced APM bonus incentive payment, which is only eligible to be earned through PY 2022, to be paid in payment year 2024. However, the additional 0.5 percent annual payment update for Advanced APMs does not go into effect until PY 2024 for payment year 2026, leaving a gap year in PY 2023 in which there is less incentive for providers to participate in an Advanced APM. This is not reflective of the intent of MACRA, which was designed to increase provider participation in value-based payment models. The Value Act aims to resolve this issue by extending the Advanced APM bonus, as well as implementing other favorable policy changes to bolster the Medicare Shared Savings Program (MSSP). We encourage you to visit our Take Action page to write your representative and urge them to extend the Advanced APM bonus. For more information on MACRA, NAACOS’ website includes internal and external resources, including the updated 2022 ACO Guide to MACRA.

Compliance Banner

JANUARY’S DIRECT CONTRACTING LEARNING DISCUSSION NOW SCHEDULED
NAACOS is holding its first Direct Contracting Learning Discussion of the year on January 21. As in 2021, these monthly events are meant for DCEs to share feedback, questions, concerns, and points of interest. Unlike last year, we are limiting participation to those participating in the model in 2022. As such, advanced registration is required.

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


2021 QUALITY REPORTING UNDERWAY
CMS recently announced the MSSP quality reporting submission period will be open from January 3, 2022, to March 31, 2022. As a reminder, 2021 is the first year the 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.
Welcome New Multi-ACO Member

Alignment Healthcare
Raleigh, NC
NAACOS SPRING 2022 CONFERENCE TOPICS ANNOUNCED
ACOs, DCEs, and other models focusing on population health can create a future where quality is better, costs are lower, and patients are engaged. Join us in Baltimore, April 28–29, and hear from leading accountable care experts and CMS officials sharing timely and essential information for ACOs and DCEs. Optional half-day workshops on April 27 will provide in-depth tutorials on addressing key issues for ACOs and DCEs. The conference will feature sessions focusing on:
  • Critical Policy Update for ACOs and DCEs
  • Increasing Health Equity
  • Quality Management Across Contracts
  • Using Data in Benchmarking
  • Clinical Transformation Through Data
  • Incorporating Episode Payment Inside Total Cost of Care Models
  • Digital Care Including Remote Monitoring
  • Effective Contracting Strategies with SNFs
  • Understanding Direct Contracting Compliance & Operations
  • Best Practices with Annual Wellness Visits
The conference will also include our peer-to-peer exchanges, and our popular CMS Townhall will close out our conference. Full agenda will be announced soon!

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. 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! Proof of vaccination required to attend in-person.

Exhibitors
The NAACOS Spring 2022 Conference will feature exhibitors with products and services specifically for the accountable care community. NAACOS Partners are the only non-ACOs allowed to attend, exhibit and sponsor NAACOS conferences. Reserve your space today!


SEND YOUR SUBMISSIONS FOR LEADERS IN QUALITY EXCELLENCE
The NAACOS Leaders in Quality Excellence Awards have been established to recognize the outstanding efforts among ACOs working to improve the quality and safety of patient care and advance population health goals. NAACOS ACO member organizations can submit an entry for a quality project through February 4, 2022. NAACOS will recognize the top three submissions, selected by the NAACOS Quality Committee, at our Spring 2022 Conference to showcase the exemplary efforts in quality improvement among our members and to disseminate best practices. More information on the award criteria and submissions process are available. Should you have any questions, please contact us at [email protected].


CMS UPDATES QPP STATUS TOOL TO INCLUDE THIRD 2021 SNAPSHOT
CMS recently updated the QPP participation status tool to reflect the third snapshot period for PY 2021 evaluation for meeting Advanced APM thresholds, known as Qualifying APM Participant (QP) thresholds. Meeting or exceeding those thresholds is required to earn the annual Advanced APM bonus for PY 2021, which will be paid in 2023. The update also reflects APM status for MIPS.

This snapshot period focused on January 1 through August 31, 2021. Importantly, many more ACOs and providers are eligible to earn Advanced APM bonuses as a result of NAACOS’s advocacy to prevent the QP thresholds from rising in 2021 and 2022 as they were previously scheduled to before Congress changed them. To learn more about these bonuses, QP thresholds, and how to qualify, please refer to NAACOS’s resource, The ACO Guide to MACRA.


CMS PUBLISHES PROPOSED CHANGES TO MEDICARE ADVANTAGE PLANS
CMS earlier this month published a proposed rule that makes updates for providers of both Medicare Advantage and Part D prescription drug benefit plans. Among the changes proposed are greater standards for proving that MA plans offer an adequate network of providers and more transparency in medical-loss ratio reporting. There was nothing noteworthy that directly relates to ACOs and value-based care entities in traditional Medicare. A final rule is expected this spring and will take effect in 2023. More information can be found in the CMS fact sheet. NAACOS will watch for additional changes in the upcoming annual call letter.



CMS PROPOSED LIMITED COVERAGE OF NEW ALZHEIMER’S DRUG
Following NAACOS advocacy, CMS announced this week that it would only cover a controversial new Alzheimer’s drug for patients enrolled in clinical trials that further study the drug’s effectiveness. The process is called “coverage with evidence development.” NAACOS wrote CMS last summer with a similar request for limited coverage, following its approval. The drug in question, Aduhelm, would be covered under Part B and counted as ACO expenditures, but many have questioned its clinical benefit. The annual price of the drug was recently cut in half to $28,000, which is still almost three times the average annual spending on a Medicare beneficiary. This week’s decision is only preliminary, and a final coverage policy is due in April.

KIDNEY CARE CHOICES MODEL PARTICIPANTS ANNOUNCED
CMS has named 30 practices participating in Kidney Care First and 55 organizations in Comprehensive Kidney Care Contracting (CKCC), both of which kicked off this month. CKCC is the kidney care-specific alternative to Global and Professional Direct Contracting. Seven of the kidney contracting entities have selected the Global Option, 37 have selected the Professional Option, and 11 have selected the Graduated Option (Level 1 or Level 2). More information on the Kidney Care Choices Model is in this NAACOS resource.

NAACOS is closely watching for CMS to announce new classes of participants in other alternative payment models, including MSSP and Global and Professional Direct Contracting. We will alert members when those announcements are made.