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Newsletter for Members
and Partners
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July 02, 2020
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NAACOS URGES FURTHER COVID-19 PROTECTIONS FOR NEXT GEN ACOS
NAACOS recently sent a letter to the Innovation Center thanking the center for extending the Next Generation (Next Gen) Model for an additional year and providing support for ACOs in the face of COVID-19. While we are pleased with the effort to adapt the model in response to the pandemic, we are urging the Innovation Center to modify certain policies and implement additional changes, including requests to:
- Enact COVID-19 protections for all Next Gen ACOs outside of the optional amendment, specifically prorating potential ACO losses by the proportion of months in the Public Health Emergency (PHE);
- Clarify aspects of what triggers a COVID-19 episode, such as by counting COVID-19 diagnoses that are not primary diagnosis codes;
- Provide ACOs more flexibility with shared savings/loss caps, such as through election of a symmetrical cap ranging from 2 percent to 8 percent, rather than only offering a 5 percent cap;
- Make quality pay-for-reporting only for Performance Year (PY) 2020 and minimize burdens associated with quality reporting and audits;
- Modify PY 2021 beneficiary alignment to address disruptions from COVID-19 by extending the alignment window to 24 months and push back the cutoff for voluntary alignment;
- Minimize burdens with updating provider lists by not requiring ACOs to use the Provider List Submission Tool and instead use the ACO User Interface; and
- Improve existing benefit enhancements and introduce new ones that would be helpful with patient care during COVID-19.
This advocacy is in response to recent announcements to the Innovation Center and corresponds to many of the requests we recently made for ACOs in the Medicare Shared Savings Program (MSSP).
CONGRESS SPRINTS TO SUMMER RECESS
On June 29, the House passed legislation to expand the Affordable Care Act’s (ACA) tax credits, push states to expand their Medicaid programs, and allow the federal government to negotiate drug prices. While the legislative package is not expected to be considered in the Senate, it highlights the healthcare priorities of the House Democratic Caucus ahead of the election.
In the coming days, the Appropriations Committees in the House and Senate are expected to begin drafting and voting on Fiscal Year 2021 spending bills. The Senate Finance Committee is also working to reintroduce a drug pricing package that Chairman Charles Grassley (R-IA) wants Senate leaders to prioritize before the end of the year.
Lawmakers will also be negotiating another COVID-19 relief package in the coming weeks. Administration officials have been testifying before Congress warning lawmakers that the economic recovery could stall if emergency health preparedness and fiscal measures end too soon. A vote is expected in late-July before Congress departs for their annual August district work period.
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| Welcome New ACO Member |
ACO Health Partners
Jacksonville, FL |
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CMS CLARIFIES NO SEQUESTRATION CUTS TO SHARED SAVINGS PAYMENTS
In a new FAQ (see question 22, MSSP section), CMS clarifies the 2 percent sequestration reduction will not be applied to ACO shared savings payments for PY 2019 shared savings, which CMS anticipates paying during the fall 2020 timeframe. This is due to the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which temporarily suspends the sequestration cuts applied to all Medicare payments. The suspension is effective for claims of service from May 1 through December 31, 2020. More information is available in this Medicare Learning Network (MLN) article.
DIRECT CONTRACTING APPLICATION DEADLINE CLOSES JULY 6
Applications to participate in the new Direct Contracting Model starting in its first performance period are due at midnight ET on July 6. That performance period will start on April 1, 2021, and run through December 31, 2021. Organizations who were accepted for Direct Contracting’s Implementation Period have until July 24 to select their start date, which can be either October 2020, April 2021, or January 2022. CMS has announced that it will offer a second application cycle to start on January 2022, which NAACOS had advocated for. That application cycle should take place early next year.
Our dedicated Direct Contracting webpage has more information and member resources, including frequently asked questions, an in-depth analysis and charts comparing Direct Contracting to other Innovation Center models and high-risk ACOs. At the NAACOS Virtual Conference last week, we hosted a session on Direct Contracting and recently announced changes.
IAC’S NEW SERVICE CALCULATES QP SCORES BY PHYSICIAN GROUP
The Institute for Accountable Care (IAC) is now using its Medicare claims database to help MSSP ACOs understand the marginal contribution of each of its physician groups (TINs) to its overall Qualifying APM Participant (QP) score. In order for eligible clinicians to earn the 5 percent Advanced Alternative Payment Model (APM) bonus ACOs must receive at least 50 percent of Medicare Part B payments or see at least 35 percent of Medicare patients through an Advanced APM entity during one of three determination (i.e., snapshot) periods. IAC can use its data to model the impact of different TIN configurations on an ACO’s 2021 QP scores. This service is provided for a fee. If you would like to learn more, please contact the Institute by email at [email protected].
NAACOS SUPPORTS TELEHEATH EXPANSION POST-COVID
NAACOS recently joined two letters from many healthcare stakeholders asking Congress to make permanent some of the recent waivers that expand the use of telehealth during the COVID-19 PHE. Outside of emergencies, CMS has limited authority to reimburse for telehealth, although two-sided MSSP ACOs that use prospective attribution can treat patients regardless of their location, including the patients’ home. NAACOS expects Congress to act this year to expand telehealth, and we are very supportive of those efforts. One letter had more than 70 organizations join and another had more than 340 organizations join.
QPP ANNOUNCES 2020 MIPS HARDSHIP EXEMPTION FOR COVID-19
On June 24, the Quality Payment Program (QPP) announced it will permit individuals and groups to submit a Merit-Based Incentive Payment System (MIPS) hardship application if the COVID-19 pandemic is preventing the collection of data for an extended period of time, or if it could affect performance on cost measures. Those approved will have performance categories reweighted to 0 percent. Note, this does not include ACOs, and, therefore, we expect the QPP to address 2020 QPP policies for COVID-19 for ACOs in future guidance and/or rulemaking.
CMS CLARIFIES TELEHEALTH’S IMPACT ON ACO ATTRIBUTION
Following NAACOS advocacy, CMS clarified to NAACOS that all services listed in §425.400(c)(1)(iv) and, therefore, used in ACO assignment will be counted in attribution when delivered via telehealth. NAACOS had asked CMS to clarify since its May 8 interim final rule with comment was not clear on this issue. However, CMS told NAACOS that all codes listed in §425.400(c)(1)(iv) were considered in assignment when delivered via telehealth even before the COVID-19 PHE. That will continue to be the case after the emergency. NAACOS is grateful for this clarification. We have updated our member resource on telehealth during the COVID-19 PHE to reflect this clarification.
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| Welcome New Associate ACO Member |
Genesis Integrated Health Network
Zanesville, OH |
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PHYSICIAN COMPARE PREVIEW PERIOD NOW OPEN
The Physician Compare website will post ACO performance on 2018 quality measures beginning this fall. Measure performance should match the rates listed in your ACO’s 2018 quality performance reports, listing 17 measures for ACOs. The Physician Compare preview period opened June 22, however, unfortunately CMS notes ACO measures will not be available to preview during this time. ACOs should instead check their scores in the fall to ensure the information listed for your ACO is accurate. Should you have any issues, CMS instructs emailing [email protected].
SUMMARY OF MEDPAC REPORT NOW AVAILABLE
A new member resource summarizing the annual June Medicare Payment Advisory Commission (MedPAC) report to Congress is now available. The report devoted two chapters to value-based payment, which we have summed up. One chapter, in which MedPAC asserted that the development of alternative payment models and care delivery models needs to accelerate, suggested having ACOs take on responsibility for prescription drug spending and improving the incentives to engage with beneficiaries as ways to increase ACO savings. In a separate chapter, MedPAC recommended that ACO assignment and benchmarks be based on national provider identifiers (NPI), rather than taxpayer identification number (TIN), as a way to reduce the potential for fraud and unwarranted ACO savings.
COVID-19 CHANGES FOR CAHPS, QMV AUDIT
CMS recently updated a FAQ document (refer to the Shared Savings section), noting that 2020 Consumer Assessment of Healthcare Providers and Systems (CAHPS) for ACOs list of survey vendors and vendor authorization tool will not be provided at this time, as CMS continues to monitor the impact of COVID-19. Additionally, CMS notes it is currently conducting a review of 2019 quality to determine whether the MSSP will forego a 2019 Quality Measures Validation (QMV) Audit process. The Next Gen ACO Model has already announced a cancelation of the QMV Audit process for 2019 for Next Gen ACOs.
SAVE THE DATE FOR THESE JULY WEBINARS!
ACO Operational Continuity: Revenue Recovery, Operational Excellence in Today’s Economic Environment
July 15 from 1:00 to 2:00 pm ET
Moderator: Alex Kasdan, Del Morgan & Company
Panelists: Don Navarro, John D. (Jack) Kearney, Sr.; Edward Bujold MD, FAAFP
ACO leaders are encouraged to join us for a presentation to understand the “where” and “how” to access emergency funds under programs identified in the CARES Act. COVID-19 is having unprecedented financial impact on urban and rural healthcare systems and providers. This presentation will share methodologies on how to identify insurance claims underpayments, insights into the management of claim denials and methods to automate appeals as a means for additional financial recovery and much improved cash flow, as well as how to use this information to negotiate more favorable payor contracts.
Register Now! Registration is limited to ACOs, regardless of NAACOS membership status.
Learn How Covenant Health and Scripps ACO Use Claims-Based Analytics to Manage Risk Contracts
July 23 from 2:00 to 3:00 pm ET
Moderator: Cathy Shea, Milliman
Speakers: John Hanaway, Charlie Mills, Tina Zhou from Milliman; Gabrial Gomez, Scripps Accountable Care Organization, LLC; Jennifer Le, Covenant ACO
If you are just beginning to or are already managing multiple risk contracts, high quality data aggregation is essential. Using claims data is key to assessing your ACO’s financial performance against the benchmark target, identifying opportunities for improvement, and achieving your shared savings goals. Another key to success is measuring the performance of the ACO provider network, specifically cost, utilization, and efficiency. Having quality data, knowing your financial performance, and understanding your provider network are three key reasons you need claims data to manage your risk contracts. Join Covenant Health, Scripps ACO, and Milliman MedInsight to learn about real world examples from your peers about the importance of claims-based analytics.
Register Now! Registration is limited to ACOs, regardless of NAACOS membership status.
If your company is interested in sponsoring a webinar for ACOs, please contact [email protected] for more details.
CMS RELEASES COVID-19 MEDICARE DATA
CMS Administrator Seema Verma used a release of COVID-related data last week to make a call to change current payment structures to better incentivize social determinants of health. In a blog on CMS’s website, Verma singled out the need to pay for outcomes, rather than the volume of services, as a way to address health disparities. CMS said that more than 325,000 Medicare beneficiaries were diagnosed with COVID-19 between January 1 and May 16, and nearly 110,000 of them were hospitalized. Of those hospitalized, 28 percent died. Nine percent of hospitalizations were longer than 21 days. Medicare payments for fee-for-service hospitalizations totaled $1.9 billion, with an average of $23,094 per hospitalization.
NQF ISSUES REPORT ON FUTURE OF HEATLH CARE
The National Quality Forum (NQF) recently convened a group of health care leaders and experts to discuss the future of health care quality and payment, The National Quality Task Force. The result of this group’s work is a recently issued report, The Care We Need, Driving Better Health Outcomes for People and Communities. NAACOS CEO, Clif Gaus, contributed to this report through his participation on this Task Force. The report focuses on addressing health care quality, safety, and value as well as patient experience and envisions a system in which every person in every community can expect to consistently receive high quality care by 2030. The report identifies actionable opportunities to improve alignment across the delivery system to achieve better health outcomes and value for every person and encourages policymakers to take such actions.
JULY CHANGE REQUEST DEADLINE APPROACHES
As a reminder, ACOs have until noon ET on July 20 to make a series of initial change requests for PY 2021. These include “freezing” your participation on the Basic Track’s glidepath, electing an additional performance year if your contract is set to expire at the end of 2020, adding or deleting ACO participants, applying for a Skilled Nursing Facility Three-Day Stay Waiver, choosing assignment methodology, and selecting a minimum savings rate (MSR)/minimum loss rate (MLR) if moving to a risk-based track. More information can be found on CMS’s website on MSSP application.
BPCI-A EVALUATION RELEASED
The latest evaluation of the Bundled Payments for Care Improvement Advanced (BPCI-A) Model was recently released, studying the model’s results from October 2018 through March 31, 2019. The evaluation focused on studying the episodes selected and types of participants, and it found hospitals appear to select clinical episodes for which they have higher episode payments. To date, the model has not shown significant savings.
CMS CREATES NEW OFFICE TO REDUCE REGULATORY BURDENS
CMS recently announced the creation of a new Office of Burden Reduction and Health Informatics, which will focus on reducing regulatory burden and the use of health informatics. The announcement notes the new office will also be focused on increasing engagement with stakeholders to carefully consider the impact of new regulations on health care system operations.
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