NAACOS Newsletter for Members and Partners July 29, 2021

Table of Contents
Value Act Introduced in House
NAACOS Holds Webinar, Releases Analysis of Proposed 2022 MPFS Rule
NAACOS to Require Vaccination to Attend Conference In-Person
COVID-19 PHE extended into October
CMS Releases Proposed 2022 Hospital OPPS Rule
Congress Bottlenecks Amid Multiple Deadlines
SDOH Learning Collaborative, Fall 2021
Next Steps on 2022 MSSP Change Requests
Compliance: MSSP through DCE and the Tools to Check Every Box
Next Direct Contracting Learning Discussion scheduled for August 11
APM Bonus: CMS Request for Billing Information Published
Congressional Leaders Launch SDOH Caucus

VALUE ACT INTRODUCED IN HOUSE
On July 20, U.S. Representatives Peter Welch (VT), Suzan DelBene (WA), Darin LaHood (IL), and Brad Wenstrup (OH) introduced H.R. 4587, the Value in Healthcare Act, which would modify key provisions of the Medicare Shared Savings Program (MSSP) for ACOs and improve incentives for alternative payment models to ensure successful participation. NAACOS and 13 other leading national healthcare stakeholder organizations submitted a letter of support and press release endorsing the bill upon introduction. The measure was also the focus on a NAACOS-convened congressional briefing on July 21, where Capitol Hill staff and stakeholders heard from Reps. Welch, DelBene, and LaHood, as well as NAACOS members from Advocate Aurora, MultiCare Connected Care, and OneCare Vermont. A recording of the briefing is available. We encourage ACOs to watch the briefing and share it as an educational resource on ACOs and the value-based care transition. NAACOS will continue to work to advance the Value Act and is planning additional activities to promote the legislation throughout the fall.

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NAACOS HOLDS WEBINAR, RELEASES ANALYSIS OF PROPOSED 2022 MPFS RULE
Access our proposed 2022 Medicare Physician Fee Schedule (MPFS) rule analysis to learn more about key changes to the MSSP proposed for 2022. NAACOS also recently held a webinar reviewing these changes for ACOs, including changes to quality reporting requirements, beneficiary notification policies and Quality Payment Program (QPP) updates for 2022. The webinar will be available on-demand on our website shortly. CMS is accepting comments on the proposals through September 13, and we encourage members to share your feedback with CMS on these changes.

NAACOS TO REQUIRE VACCINATION TO ATTEND CONFERENCE IN-PERSON
Join us in Washington, DC, September 29–October 1, and hear from leading ACO experts and CMS officials sharing timely and essential information for ACOs. Out of an abundance of caution and recognizing the serious threat of the Delta variant, NAACOS will limit in-person attendance to those who are fully vaccinated. If you are unable to get vaccinated, we hope that you will attend virtually.

Plenaries featuring CMS officials and healthcare experts include:
  • Jon Blum, CMS Principal Deputy Administrator and COO
  • Keynote and Book-signing featuring Dr. Robert Pearl’s latest Uncaring
  • Fireside-chat on addressing health equity challenges chaired by former NAACOS Board Chair Katherine Schneider
  • Townhall-style Q&A with CMS officials
Confirmed breakouts include:
  • Critical Policy Updates for ACOs and DCEs from NAACOS Policy Team
  • Transitioning to eCQM Reporting chaired by Jennifer Gasperini, NAACOS
  • Addressing Network Leakage and Keepage chaired by Tom Kloos, Atlantic Health MSO
  • Shared Savings and Physician Compensation chaired by Kimberly Kauffman, Best Value Healthcare
  • Innovations in On-Demand Acute Care chaired by Rob Mechanic, Institute for Accountable Care
  • Hospital at Home 2.0 chaired by Debbie Welle Powell, Essentia Health
  • Post COVID Lessons Learned, Opportunities and Challenges chaired by Rob Fields, Mt. Sinai Health System
  • Succeeding with Medicare Advantage chaired by Emily Brower, Trinity Health
  • Leveraging Your ACO’s Infrastructure for the Entire Organization chaired by Tony Reed, ChristianaCare
  • Advances in Digital Healthcare chaired by David Pittman, NAACOS
  • Opportunities to Improve Health Equity chaired by Jennifer Perloff, Brandeis University
The full agenda will be available soon!

How to Register
The online registration process will soon be updated to collect vaccination information for those who plan to attend in person. If you register or have already registered without submitting proof of vaccination, you will be contacted with instructions for submitting your vaccination card or switching to the virtual event. Register before August 27 and receive $300 off the in-person event or $100 off the webcast.

Exhibitors
The NAACOS Fall 2021 Conference will feature exhibitors with products and services specifically for the ACO community. NAACOS Partners are the only non-ACOs allowed to attend, exhibit and sponsor NAACOS conferences. Exhibit space is available on a first come, first served basis. You must sign up to reserve your space.


COVID-19 PHE EXTENDED INTO OCTOBER
HHS Secretary Xavier Becerra recently extended the COVID-19 Public Health Emergency (PHE) by another 90 days to last through October 18. It was due to expire this week, but NAACOS still expects the PHE to last at least through the end of the year, per a letter from then-acting Secretary Norris Cochran in January. A number of Medicare polices are tied to the PHE, including CMS waiving shared losses for ACOs and broad application of telehealth waivers. More information from NAACOS on COVID-19 is available. CMS is also updating this Frequently Asked Questions document on Medicare Fee-for-Service Billing, which has an entire section on MSSP.

CMS RELEASES PROPOSED 2022 HOSPITAL OPPS RULE
CMS recently released the proposed 2022 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems rule. In this rule, CMS makes updates to OPPS and ASC payments, increasing payments by 2.3 percent. In addition, the regulation proposes adjustments to the hospital outpatient and ASC quality reporting programs and modifications to the hospital price transparency requirements. Specifically, CMS proposes civil monetary penalties that could total penalties of more than $109,500 per hospital annually for noncompliance to increase compliance with the transparency requirements. The rule also includes updates to the Radiation Oncology Model to prepare for a Jan. 1, 2022 start date for this model, which was delayed as a result of the COVID-19 Public Health Emergency (PHE). More information is available in this CMS fact sheet.

CONGRESS BOTTLENECKS AMID MULTIPLE DEADLINES
The national debt ceiling is due to expire on July 31, hastening negotiations on a number of measures affecting the federal budget. Specifically, Democratic members continue work on a reconciliation package, which may include high-priority policy items such as universal pre-K education and expanded Medicare benefits to cover dental and vision services. Concurrently, bipartisan negotiators continue to work on a bipartisan infrastructure bill, although the pay-for to allow that measure to move forward remains elusive. Appropriations bills are also being marked up this week in committees. Unemployment benefits will also expire on September 6, another key deadline that members of Congress are looking toward as they plan for multiple mayoral and special elections on November 2.

SDOH LEARNING COLLABORATIVE, FALL 2021
NAACOS and the Institute for Accountable Care are offering a learning collaborative to help ACOs develop effective strategies to address social determinants of health (SDOH) affecting their patient populations. The learning collaborative will consist of a half-day in-person kick-off meeting followed by six virtual sessions that will focus on the following areas: needs assessment; resource identification; building a preferred network of community partners; evaluating closed-loop referral platforms; tracking outcomes; establishing payer partnerships; developing the business case for action; and advocacy for regulatory change and reimbursement. There is no cost to participate but interested ACOs will have to submit an application and space is limited. Additional details and a link to the application is available. Please contact us if you have any questions.


NEXT STEPS ON 2022 MSSP CHANGE REQUESTS
A change request in the ACO Management System (ACO-MS) refers to adding new information or changing existing information in ACO-MS that may require CMS approval. ACOs that submitted an application to the MSSP for a January 1, 2022 start date now have the opportunity to respond to the Phase 1 first request for information (RFI-1) by submitting change requests for ACO participants and skilled nursing facility (SNF) affiliates. The last day to add ACO participant TINs and/or SNF affiliates is August 3, 2021, and the last day to remove participants is September 10, 2021. As a reminder, these dates are still subject to change. More details about the application timeline and an application toolkit are available.

COMPLIANCE: MSSP THROUGH DCE AND THE TOOLS TO CHECK EVERY BOX
When CMS comes knocking, will you be ready? Join us on August 18 at 1:00pm ET for a compliance webinar designed to help ACOs and DCEs navigate new and existing CMS requirements. We will discuss the differences and similarities between ACO and DCE regulations, highlight new resources (including compliance manuals for MSSP and Global and Professional Direct Contracting [GPDC]) to help you kickstart your operations, and remind you of CMS red flags. This event will provide actionable steps for both ACOs and DCEs to operationalize compliance and check boxes this year in preparation for Performance Year 2022. Register now and we’ll see you then!

NEXT DIRECT CONTRACTING LEARNING DISCUSSION SCHEDULED FOR AUGUST 11
NAACOS has scheduled its next Direct Contracting Learning Discussion for August 11. The event is meant for DCEs that are participating in or planning to participate in the GPDC Model to share your feedback, questions, concerns, and points of interest. This collaborative discussion will provide a forum for shared learning. The meeting will take place over Zoom and start at 2 pm ET. It is available, and advance registration is not required. We plan to discuss quality reporting, non-emergent medical transports, among other topics. If you have issues you’d like to raise, please share them with [email protected].


APM BONUS: CMS REQUEST FOR BILLING INFORMATION PUBLISHED
Earlier this summer, CMS began issuing annual 5 percent bonus payments to those who qualify for Advanced Alternative Payment Model (APM) incentives through the QPP. These payments are related to 2019 performance, and eligible clinicians had to qualify based on Advanced APM participation and meeting Qualifying APM Participant (QP) thresholds. CMS recently published a notice about QPs for whom the agency does not have up-to-date billing information, which is necessary to issue the incentive payments. Affected clinicians need to contact CMS by November 1 to provide updated information so the agency can issue their Advanced APM bonuses. More information on the Advanced APM bonuses can be found in this CMS factsheet and guide. For additional information on Advanced APMs and the QPP, please visit NAACOS’ dedicated MACRA page with a number of resources and advocacy items.

CONGRESSIONAL LEADERS LAUNCH SDOH CAUCUS
Last week, congressional leaders launched the Social Determinants of Health Caucus, co-chaired by Representatives Cheri Bustos (D-IL), Tom Cole (R-OK), G.K. Butterfield (D-NC), and Markwayne Mullin (R-OK). Co-chairs gave introductory remarks discussing the need to recognize the health disparities crisis in this country and to take a holistic, whole-person approach to policy solutions in order to bring complete and adequate health care to all populations across the country. The five goals of the caucus will be to shine a light on how the COVID-19 pandemic has had a more devastating impact on those with negative social determinants, to create bipartisan thought leadership, to facilitate effective interventions, to discuss bipartisan efforts to address SDOH challenges, and to highlight congressional priorities to external stakeholders. The caucus has issued a request for information (RFI) to solicit feedback on challenges and opportunities in addressing social determinants and what actions Congress can take to mitigate negative impacts of SDOH. Feedback on the RFI is due by September 21, 2021.