|
NAACOS TEAMS WITH AHIP, AMA ON VBC PLAYBOOK
NAACOS, AHIP, and the American Medical Association released a playbook outlining best practices that organizations should consider when entering value arrangements. The Future of Sustainable Value-Based Care and Payment: Voluntary Best Practices to Advance Data Sharing supports the movement to value-based care (VBC) in the private sector by fostering alignment of data sharing practices. While recognizing that different entities have inherently varying needs and uses for data, five key areas of opportunity emerged:
- Create an interoperable data ecosystem
- Share more complete, comprehensive data
- Improve data collection and use to advance health equity
- Share timely, relevant, and actionable data
- Make data methodologies, calculations, and context readily and easily available
Find more information about the playbook on our website.
MAKE YOUR VOICE HEARD BY LAWMAKERS IN WASHINGTON
Sign up today! for the upcoming NAACOS Hill Day on September 20 in conjunction with the NAACOS Fall Conference. Our Hill visits have been very effective. Last fall our board members met with lawmakers during the conference, which helped secure the one-year extension of the advanced alternative payment model (APM) incentives. Earlier this year, NAACOS leaders traveled to Washington for meetings that helped create more attention on the Medicare Access and CHIP Reauthorization Act (MACRA). This resulted in a congressional sign-on letter and hearing.
- Logistics. Registration will be open for the first 75 participants, with a limit of two participants per organization. If your ACO would like to have more participants join the Hill Day, please reach out to Robert Daley for more information on how we can coordinate your ACO’s fly-in with the Fall Hill Day.
|
| WELCOME NEW BUSINESS PARTNER |
| |
 |
|
|
COMMITTEES CONSIDER HEALTH BILLS BEFORE AUGUST RECESS
As Congress prepares to depart for the August Recess, lawmakers have been busy working to advance different health care priorities. When lawmakers return to Washington after Labor Day, they will have until September 30 to extend funding for the federal government and reauthorize a long list of expiring health programs.
- House Ways and Means Committee. Voted on legislation to increase hospital and drug price transparency along with updates to site neural payments.
- Senate Finance Committee. Considered several bills to address drug prices and increase transparency for pharmacy benefit managers (PMBs).
- House Energy and Commerce Committee. Approved a series of bills that reauthorize public health and workforce programs and expand telehealth for workers.
- Senate Health, Education, Labor and Pensions Committee. Approved bipartisan legislation to reauthorize pandemic prevention programs. The committee is also working to build bipartisan support for a vote in September on a bill to expand funding for health workforce programs.
- House and Senate Appropriations Committees. House lawmakers released and considered a Fiscal Year 2024 Labor, Health and Human Services (HHS), and Education funding bill that includes significant reductions to health spending. Meanwhile, the Senate Appropriations Committee recently voted on its version of the HHS funding bill that maintains funding levels consistent with the debt ceiling agreement between the White House and Congress.
CMS RELEASES 2024 MPFS PROPOSED RULE
On July 13, CMS released the 2024 Medicare Physician Fee Schedule (MPFS) proposed rule. This rule includes positive changes for ACOs that NAACOS has been advocating for, including improvements in quality reporting, more fair benchmarking policies, a smooth transition to a new risk adjustment model, keeping advanced payments for new ACOs who transition to risk, helping ACOs who serve high-cost beneficiaries, and others. NAACOS issued a press statement on the rule and will host a webinar reviewing the proposed changes for ACOs this afternoon, Thursday, July 27 from 3:00 to 4:15pm ET. A recording and slides will be made available for those unable to attend live. NAACOS will publish an in-depth analysis of the proposed rule next week.
Key proposed changes to the Medicare Shared Savings Program (MSSP)
Assignment Methodology
- Adds a third step to the assignment process in 2025 that would expand the assignment window to two years for a physician visit; this allows the assignment methodology to better account for beneficiaries who primarily receive services from a nurse practitioner, physician assistant, or clinical nurse specialist.
- Adds several new codes to the definition of primary care services used in ACO assignment.
Benchmarks and Risk Adjustment
- Proposes to effectively eliminate the negative regional adjustment.
- Modifies its use of the CMS-HCC risk adjustment model to account for the new model version starting in 2024 by using the same model version in benchmark and performance years.
- Caps the risk score growth in an ACO’s region for agreements beginning in 2024, making the cap on the ACO and its region symmetrical.
- Seeks comment on potential further refinements to the Accountable Care Prospective Trend.
Quality
- Creates a new quality reporting option for MSSP ACOs; the Medicare Clinical Quality Measures reporting option would require ACOs to report only on Medicare beneficiaries, providing flexibility with the previous all-payer reporting requirement.
- Changes the Quality Performance Standard calculations to use historical data.
- Adjusts policies related to quality scoring requirements for suppressed measures and makes changes to Consumer Assessment of Healthcare Providers and Systems (CAHPS) measures.
- Removes Certified Electronic Health Record Technology (CEHRT) threshold requirements for certain MSSP ACOs.
- Solicits comments on Merit-based Incentive Payment System (MIPS) Value Pathways quality reporting for specialists in MSSP ACOs.
Other
- Seeks comments on the potential for an Enhanced Plus Track, which would allow higher levels of risk in MSSP.
- Modifies policies for advance investment payments (AIPs) to allow ACOs receiving AIPs to transition to a two-sided risk model under the Basic Track in Performance Year (PY) Three, to allow an exception to the recoupment policies for ACOs that early renew, to permit reconsideration of quarterly payment calculations, and to update policies related to early termination and reporting.
- Revises MSSP eligibility requirements and clarifies definitions for experience with performance-based risk.
- Seeks comments on ways to increase collaboration between ACOs and community-based organizations (CBOs).
Key proposed changes to physician payment:
- Decreases the Medicare conversion factor from $33.89 to $32.75 for 2024.
- Implements an evaluation and management visit add-on code for complexity (G2211); this code was previously delayed by Congress. CMS is proposing implementation with modifications.
- Creates new codes for community health integration services and social determinants of health (SDOH) risk assessment.
Key proposed changes to the Quality Payment Program (QPP):
- Makes all advanced APM qualifying participant (QP) determinations at the individual level only, instead of the APM entity level and modifies the attribution methodology. Makes updates to MIPS requirements for APMs.
- Increases the MIPS performance threshold from 75 to 82 points for PY 2024.
For more information on the proposed rule:
EPISODE MODEL RFI OPEN FOR COMMENT
The Center for Medicare and Medicaid Innovation (CMMI) published a Request for Information (RFI) seeking input on the design of a future episode-based payment model that aims to support accountable care and create an avenue for specialists to participate in value-based care initiatives through episode-based payment models. The model would be required in certain regions to ensure broad representation of participants and would be implemented no earlier than 2026. Comments will be solicited through August 17.
FTC WITHDRAWS TWO ANTITRUST POLICY STATEMENTS
On July 14, the Federal Trade Commission (FTC) announced its withdrawal from two health care antitrust policy statements, including the 2011 Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings Program. The announcement followed the Department of Justice’s withdrawal from the same statements in February. NAACOS has prepared a summary of the announcement.
CMMI RELEASES MODEL RESULTS
Formal evaluations of two key CMMI Models have been published.
CMS RELEASES PROPOSED 2024 HOSPITAL OUTPATIENT RULE
CMS recently released the proposed 2024 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems rule. The proposed rule, fact sheet, and press release are available. Comments are due September 11.
CMS is proposing to:
- Increase OPPS and ASC payments by 2.8 percent,
- Change hospital price transparency rules and quality reporting programs,
- Establish the Intensive Outpatient Program (IOP) for mental and substance use disorder.
NOMINATIONS FOR QUALITY REVIEW COMMITTEES NOW OPEN
The Partnership for Quality Measurement (PQM) has replaced the National Quality Forum’s consensus-based endorsement and maintenance process for quality measures used in CMS programs. The new Pre-Rulemaking Measure Review (PRMR) process will be launched this fall. Battelle is now accepting nominations for participation in committees. Specifically, the clinician committee will be responsible for reviewing measures to be used in MSSP. Individuals can nominate themselves or others, and nominations are due July 30. More information regarding membership opportunities is available on the PQM website.
OPPORTUNITY TO ADD ACO PARTICIPANTS CLOSES NEXT WEEK
ACOs applying to participate in MSSP beginning January 1, 2024, and current ACOs making modifications to their ACO participant list through the annual change request cycle must submit any additions to the ACO participant list by August 1, 2023, at 12:00 pm ET. This will also be the final opportunity for ACOs to elect to apply for the Skilled Nursing Facility (SNF) 3-day Rule Waiver and add SNF affiliate TINs. More information on the application cycle and key deadlines is available.
CMS HOSTS MCP MODEL WEBINAR FOR FQHCS
Last week, CMS hosted the second in a series of webinars on the Making Care Primary (MCP) Model, which is set to launch on July 1, 2024. This webinar was targeted towards Federally Qualified Health Centers (FQHCs) and Indian Health Programs interested in the model. The webinar slides, transcript, and recording will be made available on the MCP model webpage shortly. Organizations interested in participating in MCP can now submit a non-binding letter of intent to CMMI. More information on MCP and the model’s implications for ACOs is available.
WEBINAR ON TRANSITIONING TO ECQMS AND MIPS CQMS
NAACOS will hold a webinar on August 2 at 3:00 pm ET reviewing quality submission approaches for MSSP ACOs. Attendees will hear updates from NAACOS staff on 2024 MPFS proposed rule provisions affecting quality reporting and hear feedback from ACOs implementing these changes. Northwestern Medicine will share how its ACO is preparing for the 2025 requirement to move to electronic clinical quality measure (eCQM) or MIPS CQM quality reporting approaches.
DISCOUNT FOR CONFERENCE REGISTRATION ENDS SOON
Join us September 20-22, 2023, at the Marriott Marquis Washington, D.C. for the fall conference! In addition to our plenaries with CMS officials and other value-based care leaders, 16 breakout sessions will deliver actionable knowledge for new ACOs joining the MSSP and REACH models, rural ACOs, independent primary care ACOs, and experienced ACOs in all models. Full agenda is now available!
In conjunction with the fall conference, NAACOS is offering three concurrent workshops that take a deep dive into key issues facing ACOs. Pre-conference workshops will be held September 20 from 1:00 to 5:00 pm ET. These workshops require separate registration from the main meeting.
Virtual and in-person registration options are available and, as always, the entire conference will be recorded. Register early and save! Register before August 4 for the in-person or virtual conference and receive a discount.
Exhibitor and sponsor opportunities are now available and going fast! The conference will feature exhibitors with products and services specifically for the accountable care community. Check out the prospectus for new and fun opportunities as partners. Partners reserve your space today!
NAACOS PARTNER MEMBERSHIP CALL
Join us on August 4 at 11:00 am ET for an engaging and informative call for NAACOS Business Partners, where you’ll gain valuable insights and updates on our latest initiatives. Connect with fellow partners, industry experts, and our dedicated team to explore collaboration opportunities and stay ahead of the curve. Don’t miss this chance to maximize the benefits of your partnership and shape the future together. Register Today! This meeting is only open to Partners.
NEXT MEDICAID LEARNING LAB SESSION ON AUGUST 4
Join the next Learning Lab meeting on August 4, 2023, from 2:00 pm to 3:30 pm ET. This meeting will focus on how NAACOS can assist our members in their journey to successful Medicaid VBC contracting. If you have previously signed up for the Medicaid Learning Lab, you can use the same link to join this meeting. If you have not signed up but are interested in joining, sign-up now.
INNOVACCER USER DISCOVERY CALL
At the request of ACO members, NAACOS will hold a discovery call for Innovaccer users on August 9 from 3:00 pm to 4:00 pm ET. This meeting will be hosted by Dr. Tom Kloos, VP Atlantic Health System and President Atlantic ACO. During the call we will gather information on challenges, compare notes, and share best practices, workflows, etc. If you are a current Innovaccer user, sign up to join this organizing call for our members.
| WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE |
|
|
