NAACOS, OTHERS ASK HHS FOR NEXT GEN EXTENSION NAACOS joined 13 other groups in a letter urging HHS Secretary Xavier Becerra to extend the Next Generation (Next Gen) ACO Model through 2022 and create a permanent full-risk ACO option based on the Next Gen Model. With the cancelation of a 2022 cohort of Direct Contracting starters, Next Gen ACOs have no other participation option next year besides MSSP Enhanced, if CMS doesn’t extend Next Gen. NAACOS doesn’t view this as being fair for ACOs who have made serious commitments to payment and delivery system reform and generated savings for Medicare. Extending Next Gen and giving those ACOs a worthy participation option next year are top policy priorities for NAACOS this year, and we will continue to advocate on these.
SUBMIT QUESTIONS FOR CMS TOWN HALL AT NAACOS CONFERENCE The NAACOS spring conference is underway! Our Town Hall featuring CMS leaders is a great opportunity for ACOs to ask these experts questions on a range of topics affecting ACOs. In addition to encouraging live audience questions during the session, we are soliciting questions we can submit to CMS in advance. Please send your questions by Monday, April 26, by emailing advocacy@naacos.com with the subject “Town Hall.”
NAACOS LETTER TO CMMI DIRECTOR LIZ FOWLER REQUESTS MODEL CHANGES NAACOS recently sent a letter to the new director of the Center for Medicare and Medicaid Innovation (Innovation Center), Elizabeth Fowler, with recommendations for strengthening ACOs and the transition to value-based care. Our letter includes broad, longer-term recommendations for CMS such as requesting that the agency:
Set a national goal to have a majority of traditional Medicare beneficiaries in ACOs by 2025,
Build a population health infrastructure and deprioritize the rush to risk for providers, and
Address overlap of competing payment models to prioritize total cost of care models.
The letter also provides detailed input on some key Innovation Center models, including making policy recommendations to improve the Direct Contracting Model, urging the agency to extend the Next Gen Model through 2022 while a permanent solution can be implemented, and expanding eligibility and scale of a new ACO loan program for rural and small ACOs. NAACOS looks forward to a productive and positive relationship with the Innovation Center under the leadership of Director Fowler.
COVID-19 PUBLIC HEALTH EMERGENCY EXTENDED THROUGH JULY HHS Secretary Xavier Becerra recently extended the COVID-19 Public Health Emergency (PHE) by another 90 days to last through July 20. It was due to expire this week, but it is likely that the PHE will last through the end of the year per a letter from then-acting Secretary Norris Cochran to governors 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 on COVID-19 is available. CMS is also updating their Frequently Asked Questions document on Medicare Fee-for-Service (FFS) Billing, which has an entire section on MSSP.
DIRECT CONTRACTING’S PY1 PARTICIPANTS ANNOUNCED The CMS Innovation Center announced the 53 organizations participating in Performance Year (PY) 2021 year of Global and Professional Direct Contracting Model, and NAACOS congratulated them in a statement. This initial class includes 39 Global Direct Contracting Entities (DCEs) and 14 Professional DCEs, with 31 Standard DCEs, 16 New Entrant DCEs, and six High Needs DCEs. There were 30 DCEs who participated in the model’s optional Implementation Period that did not move into the first performance period.
CMS also announced the Innovation Center will not be soliciting applications for organizations wanting to start the model in 2022. This is disappointing to those anticipating a chance to join the model, especially Next Gens, but NAACOS views this pause as a chance to review the model and make it more attractive to successful ACOs, which we have previously said are disenfranchised by the model’s rules.
FIRST NAACOS LEADERS IN QUALITY EXCELLENCE AWARD WINNERS ANNOUNCED Essentia Health, Ochsner Accountable Care Network, and Primaria Health were presented with the NAACOS Leaders in Quality Excellence Award during the NAACOS Spring 2021 Conference. The distinction recognizes ACOs working to improve the quality and safety of patient care and advance population health goals in their communities. From the field of ACOs submitting projects, the NAACOS Quality Committee selected the top three to showcase the quality improvement efforts undertaken by NAACOS members and to disseminate best practices. The three inaugural winners exemplify how ACOs across the country are improving care by addressing food insecurity, making house calls to reduce preventable emergency department visits, and engaging patients in preventive services. NAACOS further recognized these ACOs in a press release and document highlighting their work.
ACOS RAISED AT BROOKS-LASURE SENATE FINANCE HEARING On April 15, the Senate Finance Committee held a hearing to consider the nomination of Chiquita Brooks-LaSure to be the administrator of the Centers for Medicare and Medicaid Services (CMS) and Andrea Palm to be the Deputy Secretary of the U.S. Department of Health and Human Services (HHS). During the hearing, the issue of ACOs and value-based care was raised by Senator Sheldon Whitehouse (D-RI) and led to a productive exchange with CMS Administrator nominee Brooks-LaSure, who noted that “we want to make sure that our private sector stakeholders want to continue to innovate, and…make sure that our incentives continue to keep innovators wanting to innovate.” NAACOS also submitted a statement for the record to the committee highlighting policy issues of concern for ACOs. While Brooks-LaSure’s swift confirmation had been anticipated, on April 20 Senator John Cornyn (R-TX) put a hold on her nomination, which may complicate Brooks-LaSure’s confirmation.
REGISTRATION OPEN FOR JUNE BOOT CAMP ON ACO DATA Harnessing your data can create actionable strategies that improve your ACO’s performance. Bring your team to a virtual training on Maximizing the Power of Data in Your ACO on June 22 and 23. Learn from leading ACOs how to turn your data into knowledge that will guide your operations and put your ACO on the path to success. Boot camp faculty will:
Answer the “Buy vs. Build” dilemma
Review accessing and using basic ACO data
Demonstrate how to close care gaps
Prepare your ACO to handle electronic Clinical Quality Measures (eCQMs)
Plus learn from ACO colleagues during three Zoom debrief sessions, held throughout the two-day boot camp.
This boot camp is designed for the ACO executive team, specifically executive directors, medical directors, population health leaders, and data/analytics teams. NAACOS ACO members save at least $200 per registration. Group rates also available to NAACOS ACO members.
Clover Health – Jersey City, NJ Team Health – Knoxville, TN
CONGRESS CONTINUES WORK ON AMERICAN JOBS PLAN This week Congress continues to negotiate elements of the first infrastructure plan released by the Biden administration, the American Jobs Plan, which also includes funding for home-based and community services and long-term care, corporate tax increases, and broadband investment. The second phase of Biden’s infrastructure plan, which is expected to focus more on “human infrastructure” and may include drug pricing and Affordable Care Act (ACA) expansion measures, has not yet been formally released but is being discussed by policymakers. Speaker Pelosi has set a deadline of the July 4th Recess for consideration of the American Jobs Plan, and the advancement of this legislation may depend on whether and how the reconciliation process is used, and to what extent lawmakers can coalesce around bigger ticket items.
CMS UPDATES QUALITY BENCHMARKS FOR 2021 CMS recently released an updated set of the Merit-based Incentive Payment System (MIPS) benchmarks, which will be used for performance year (PY) 2021 quality reporting. These benchmarks include the three measures in the Alternative Payment Model [APM] Performance Pathway (APP) measure set that can be reported as an eCQM or MIPS CQM. In this updated version, CMS identified that the eCQM version of Quality ID# 134: Preventive Care and Screening: Screening for Depression and Follow-up Plan had substantive changes, and as a result the benchmark for this reporting option was removed. Data from all MIPS participants reporting the eCQM for the current year will be used to set the benchmark, which differs from how reporting on this measure will be scored via the Web Interface.
As a reminder, ACOs who choose to report via the Web Interface will be evaluated against a different set of benchmarks. Those benchmarks are set using flat percentages for seven of the 10 measures in the APP measure set. Three Web Interface measures must be reported but will not be scored in 2021: Statin Therapy for the Prevention and Treatment of Cardiovascular Disease (Quality ID# 438); Depression Remission at Twelve Months (Quality ID# 370); and Preventive Care and Screening: Screening for Depression and Follow-up Plan (Quality ID# 134).
PAYMENT RULES FOR POST-ACUTE FACILITIES PROPOSED BY CMS CMS estimates in a recently published proposed rule that payments to skilled nursing facilities will increase by 1.3 percent or roughly $444 million in 2022. That does not account for reductions from the value-based program. CMS proposes to recalibrate the new Patient Driven Payment Model, along with other changes, according to a CMS fact sheet. CMS is also proposing to increase hospice payments by 2.3 percent or $530 million in 2022, according to the proposed rule and related fact sheet. Lastly, Inpatient Rehabilitation Facilities (IRF) are estimated to receive a 2.2 percent payment increase in 2022 in a separate proposed rule. CMS also outlines several changes to IRF’s Quality Reporting Program, according to a CMS fact sheet.
CMS EXTENDS PRIMARY CARE FIRST APPLICATION DEADLINES CMS recently announced that the agency will extend the application period for the second cohort of the Primary Care First (PCF) Model, which is scheduled to begin in January 2022. The Request for Applications (RFA) for Cohort 2 was released in March. The deadline for practices to apply for PCF Cohort 2 is May 21, 2021, and the deadline for payers to apply to partner with CMS in PCF Cohort 2 is June 18, 2021. Earlier this year, CMS also announced that participation in the Comprehensive Primary Care Plus (CPC+) Model would no longer be a requirement for PCF Cohort 2 eligibility, so all practices within the 26 regions meeting other requirements are eligible to apply.
There are currently 827 practices participating in Cohort 1 of PCF and 14 payer partners. Practices in both Cohort 1 and Cohort 2 will have a five-year performance period.
Consistent with Tracks 1 and 2 of the CPC+ Model, practices participating in ACOs under all MSSP tracks are eligible to participate in PCF. In contrast, providers participating in the Direct Contracting Model may not simultaneously participate in PCF.
CMMI BUNDLED PAYMENT MODEL SHOWS NET LOSSES A pair of formal evaluations of the CMS Innovation Center’s bundled payments model showed net losses to Medicare. The final evaluation of the Bundled Payments for Care Improvement (BPCI) Initiative found Medicare ultimately lost money after accounting for reconciliation payments to participants. The evaluation showed that quality was at least maintained. Both findings were consistent with previous reports. The full report and Findings-at-a-Glance are available online.
The BPCI Advanced Model, which is the successor model that launched in the fall of 2018, also found participating hospitals reduced Medicare FFS payments for most of the clinical episodes evaluated while maintaining quality of care through year three. However, Medicare experienced net losses in the first ten months of the model after accounting for reconciliation payments. CMS made significant design changes to the model starting this year. The full report and Findings-at-a-Glance are available online.
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