Newsletter for Members and Partners July 18, 2019
Table of Contents
CMS Announces 2019 MSSP Class
NAACOS Meets with CMMI Leaders to Discuss Direct Contracting Model
NAACOS Advocacy Results in Changes to ACO-17 for PY 2018
CMMI Releases Several New Kidney Care, Radiation Oncology Models
Upcoming NAACOS Webinar on Addressing Social Determinants in ACOs
Application Deadlines Fast Approaching
NAACOS Meets with Lawmakers on ACOs
CMMI Director Adam Boehler Departs CMS
2018 MIPS Scores Now Available
NAACOS Medicaid ACO Webinar Now Available On-Demand
BPCI-A Issues Letter to Participants Regarding MSSP Overlap
HHS Quality Summit Announced
2018 Performance Results to be Released Soon
FCC Proposed New $100 Million Telehealth Pilot Program
CMS ANNOUNCES 2019 MSSP CLASS
CMS this week released information on the ACOs participating in the MSSP as of July 1, 2019, including those participating in the new “Pathways to Success” structure. That information is available on this webpage. There are 518 total ACOs in MSSP, with 152 (29 percent) participating in two-sided risk tracks. Forty-one are participating in the new Basic Level E and 72 in the new Enhanced Track, qualifying as Advanced Alternative Payment Models. NAACOS congratulates new ACOs joining MSSP and those continuing in the program.
NAACOS issued a press release calling attention to the roughly 40 new ACOs. While these numbers represent a smaller number of new ACOs from the more than 100 the program has averaged since 2012 and a drop in overall MSSP participation from the 561 we saw in 2018, NAACOS hopes this is only a reflection of an off-cycle start date and not an indication that the program and transition to value are slowing down. NAACOS looks forward to supporting and advancing the important work of ACOs by providing education, promoting best practices, and advocating for polices that help grow Medicare ACO programs and their long-term success.
NAACOS MEETS WITH CMMI LEADERS TO DISCUSS DIRECT CONTRACTING MODEL
Last week, NAACOS CEO Clif Gaus, along with senior NAACOS staff and two NAACOS Board members, met with leaders from the Center for Medicare and Medicaid Innovation (CMMI) in Baltimore to discuss the Direct Contracting Model. This meeting was part of our ongoing advocacy to influence development of the Direct Contracting Model and was a follow up to our two letters on Direct Contracting. One letter included detailed recommendations on the Professional and Global Population-Based Payment (PBP) options and the other letter provided feedback in response to the Request for Information (RFI) on the Geographic PBP option. During the meeting, we discussed many key issues related to the Direct Contracting Model, including setting appropriate benchmarks and risk adjustment, providing flexibility with beneficiary waivers/incentives for beneficiaries to receive care from high quality, efficient providers, addressing model overlap, providing real-time data to Direct Contracting entities, and allowing the option for claims processing, among others.
NAACOS ADVOCACY RESULTS IN CHANGES TO ACO-17 FOR PY 2018
NAACOS is pleased to report that our advocacy efforts have resulted in CMS changing the quality measure ACO-17 to a pay-for-reporting only measure in 2018 for MSSP and Next Generation ACOs. In Issue 27 of the ACO Spotlight Newsletter CMS notes these changes, which also specify that the measure will not be scored for purposes of Merit-based Incentive Payment System (MIPS) quality for Performance Year (PY) 2018. Lastly, ACOs should note that CMS does plan to continue to provide performance information on the measure. In upcoming comments NAACOS will also urge the agency to avoid similar situations by not making measure specification changes without ample notice, opportunity for stakeholder feedback, and ACO education. NAACOS thanks our Quality Committee, Policy Committee, and our members for helping us identify this critical issue.
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CMMI RELEASES SEVERAL NEW KIDNEY CARE, RADIATION ONCOLOGY MODELS
Last week CMMI released six new payment models targeting chronic kidney disease, end-stage renal disease (ESRD), and radiation oncology. The Radiation Oncology Model and ESRD Treatment Choices Model are both mandatory bundled payment programs with more details provided in a proposed rule. Payments made under either would be counted as expenditures under the MSSP and other shared savings initiatives. The ESRD Model encourages home dialysis for ESRD patients through monthly capitated payments and later adjusted for the performance of transplant patients. If finalized as proposed, the Radiation Oncology Model will apply a 90-day bundle to 17 cancer types regularly treated with radiation. Fact sheets on the Radiation Oncology Model can be found here and the ESRD Treatment Choices Model here. CMMI also introduced four voluntary models targeting chronic kidney disease patients. The Kidney Care First Model targets nephrology practices and their nephrologists only with capitated payments for aligned beneficiaries and a bonus for kidney transplant patients paid over three years provided the transplant remains successful. Comprehensive Kidney Care Contracting offers three levels of progressively higher risk, from shared-savings only to 100 percent risk for the total-cost-of-care of assigned patients. Few details about the overlap with ACOs are available, but CMS releases more information in this fact sheet. NAACOS has a chart of notable CMS Innovation Center models and their overlap with ACOs.
UPCOMING NAACOS WEBINAR ON ADDRESSING SOCIAL DETERMINANTS IN ACOS
On August 22 from 3:00 to 4:00 p.m. ET, NAACOS will host the webinar, Addressing Social Determinants of Health in ACOs. In this webinar, ACOs will discuss lessons learned while addressing social determinants of health (SDOH) within their organizations, potential return on investment for these strategies, and how to begin measuring and tracking your ACO’s progress in this space. Presenters will also review use of technology to support this work, staff training and composition changes to be successful, and what care plan modifications are necessary to make meaningful changes. Click here to register. This webinar is free for members and partners, and $195 for non-members.
APPLICATION DEADLINES FAST APPROACHING
ACOs have until 12:00 p.m. ET on July 29 to apply to participate under the new Pathways to Success program structure starting January 1, 2020. CMS offers more detail on the application process on its website. More information about the new MSSP structure created by the Pathways to Success Rule is available in our member analysis.
Letters of Intent to apply for either the professional or global options of the new Direct Contracting Model are due by 12:00 a.m. August 2. Letters aren’t a commitment to formally apply later but are required if you wish to submit an application later. For ACOs not interested in participating in Direct Contracting in 2020 but who are wishing to start in 2021, CMS staff has told NAACOS that those ACOs must still submit a letter of intent and an application this year. CMS has yet to release application information for the Primary Care First Model, which was announced in April. Visit the NAACOS page dedicated to Primary Care First and Direct Contracting to find more information on either model.
NAACOS MEETS WITH LAWMAKERS ON ACOS
Over the past several weeks, NAACOS, along with other leading healthcare trade associations active on ACO issues, have met with House and Senate lawmakers and staff to discuss reintroduction of an updated version of the ACO Improvement Act. These meetings have been strategically focused on committees of jurisdiction, House Ways and Means and Energy and Commerce Committees, and the Senate Finance Committee. Topics discussed include improvements to the MSSP to encourage and promote ACO participation and updates to the Advanced Alternative Payment Model (Advanced APM) provisions of the Medicare Access and CHIP Reauthorization Act (MACRA). Feedback on reintroduction of the ACO Improvement Act has been positive, and NAACOS will continue to press on Capitol Hill for advancement of this important measure. NAACOS also appreciates those members who have weighed in directly with their congressional representatives in support of reintroduction.
CMMI DIRECTOR ADAM BOEHLER DEPARTS CMS
Adam Boehler, the CMS deputy administrator and director of CMMI, is leaving CMS after a little more than a year. During his time at CMMI, he focused on advancing the transition to value-based payment models and worked on developing a number of new models that are being implemented, such as the Direct Contracting Model. Mr. Boehler has been nominated for another federal position, CEO of the U.S. International Development Finance Corp., an agency recently formed under the Trump administration that oversees finances of projects in foreign countries. NAACOS looks forward to continuing its collaboration with CMMI leaders and a new director, once appointed.
2018 MIPS SCORES NOW AVAILABLE
CMS recently provided preliminary 2018 MIPS scores, available on the Quality Payment Program (QPP) portal. Note that a perfect score of 100 points will earn a 1.68 percent positive payment adjustment in 2020. CMS also shared certain aggregate MIPS results, notably that the number of Qualifying Advanced Payment Model Participants (QPs) nearly doubled from 99,076 clinicians in 2017 to 183,306 clinicians in 2018 due in large part to increasing participation in the the MSSP. Only 1.95 percent of clinicians fell below the established performance threshold, resulting in MIPS penalties, therefore MIPS bonus amounts remain minimal in PY 2018, which corresponds to 2020 payment adjustments. To learn more about how MIPS applies to ACOs specifically, please refer to our ACO Guide to MACRA.
NAACOS MEDICAID ACO WEBINAR NOW AVAILABLE ON-DEMAND
A number of state Medicaid programs have implemented value-based payment arrangements, including some states that focus their programs around ACOs. While accountable care programs vary across states, there are some common Medicaid-specific challenges and approaches. NAACOS recently reviewed state Medicaid ACO initiatives during a 75-minute webinar, Understanding the Medicaid ACO Landscape, which is now available on-demand. This webinar includes a presentation by NAACOS consultant Judy Moore, who has worked with state and federal Medicaid programs for several decades, and it also includes individual ACOs sharing their experiences and describing recent ACO developments in their state’s Medicaid programs. This webinar is a member benefit and can be accessed on-demand here.<
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Recently CMMI issued a notice to Bundled Payments for Care Improvement-Advanced (BPCI-A) participants regarding changes in the overlap policy for MSSP. The email notes the following:
For Model Year 1 and 2 reconciliation calculations, BPCI-A includes expenditures for items and services furnished to beneficiaries assigned to MSSP Tracks 1, 1+, 2, and Basic Track (Levels A through E) and excludes from reconciliation calculations expenditures for items and services furnished to beneficiaries aligned to Enhanced Track (formerly known as Track 3).
For Model Year 3 reconciliation calculations, BPCIA will include expenditures for items and services furnished to beneficiaries assigned to MSSP Tracks 1, 1+, 2, Basic Track (Levels A through E), and Enhanced Track. Therefore, BPCI-A will no longer exclude beneficiaries aligned to an MSSP track. CMS will continue to exclude beneficiaries aligned or assigned to an ACO participating in the Next Generation ACO Model, Vermont All-Payer ACO Model, and the Comprehensive ESRD Care Initiative in tracks with downside risk for financial losses.
This is a departure from previous CMS policy, and NAACOS is disappointed to see CMS make this change. NAACOS will continue to advocate for overlap policies that prioritize the total cost of care models by giving precedence to those responsible for a patient’s total cost of care and health of the entire patient population.
HHS QUALITY SUMMIT ANNOUNCED
The Department of Health and Human Services (HHS) recently announced an upcoming Quality Summit. The goal of the summit is to create a discussion forum about how HHS can formulate a Health Quality Roadmap that will align and improve reporting on data and quality measures and identify burdensome regulations and mechanisms needed to improve providers’ ability to deliver high-quality care. Summit participants will be comprised of government stakeholders and approximately 15 non-government healthcare industry leaders. Nominations for participants may be submitted July 9 through July 31. To submit a nomination, send a one-page cover letter summarizing qualifications along with a resume or curriculum vitae by e-mail to [email protected] with the subject line “Quality Summit Application.”
2018 PERFORMANCE RESULTS TO BE RELASED SOON
ACOs will soon learn if they achieved shared savings in 2018. CMS has told Next Generation ACOs they are targeting the end of July to distribute final 2018 performance results. Preliminary Settlement Reports were sent on May 20. Preliminary reports did not include non-claims-based payments or final quality scores. For MSSP, quality results are expected soon with financial results expected to be delivered around mid-August.
FCC PROPOSES NEW $100 MILLION TELEHEALTH PILOT PROGRAM
The Federal Communications Commission (FCC) is working to establish a three-year, $100 million Connected Care Pilot that subsidizes broadband-enabled telehealth services that connect patients directly to their doctors. The proposed pilot would provide an 85 percent discount on broadband technology. It would join the FCC’s Rural Health Care Program, which provides up to $571 million annually to connect rural health providers to deliver telehealth services. The proposed Connected Care Pilot is envisioned to connect providers with patients. NAACOS last fall responded to the FCC’s Notice of Inquiry for expanding telehealth for low-income consumers, and our comments were mentioned in the FCC’s proposed rule