NAACOS MEMBERSHIP SATISFACTION SURVEY IS NOW LIVE! Attention ACO members: On August 4, NAACOS launched a membership satisfaction survey to its ACO members via email. The email titled “NAACOS needs your feedback!” is ready for your input and contains a link for you to complete. We want to hear from you! How are we doing? What can we be doing better? Please take five minutes to complete the survey as it will help guide NAACOS on future programming and resources to help your ACO succeed. If you have questions on accessing your link, please email our team at membership@naacos.com. We thank you in advance for your thoughts and recommendations!
Welcome New Business Partners
Acadia Acadia aspires to enable brighter moments for patients and their loved ones. Our late-stage development efforts are focused on dementia-related psychosis, negative symptoms of schizophrenia and Rett syndrome, and in early-stage clinical research we are exploring novel approaches to pain management, and cognition and neuropsychiatric symptoms in central nervous system disorders. acadia-pharm.com
Coverys Coverys provides downside financial risk protection for CMS program participants, including nearly all Value-Based Care programs. The insurance coverage underwritten by Coverys protects the participanting organization from the downside risk assumed in these programs, while allowing providers to take full advantage of the upside financial benefits. coverys.com
Anelto At Anelto, our mission is to help seniors thrive. Our leading technology platform enables innovative healthcare solutions for seniors, allowing them to stay connected to their healthcare providers from anywhere. anelto.com
nirvanaHealth nirvanaHealth is focused on leveraging robotic process automation, machine learning, and artificial intelligence to simplify healthcare management, reduce cost, and improve quality across the payer and pharmacy benefit management ecosystems. nirvanahealth.com
BioReference Laboratories BioReference provides comprehensive testing to physicians, clinics, hospitals, employers, government, correctional institutions, and medical groups. bioreference.com
PreSquared University Startup using patent-pending machine learning models to identify beneficiaries at the highest risk of avoidable hospital events. presquared.com
CMS DELIVERS INDIVIDUAL MSSP ACO RESULTS FOR PY 2020 Medicare Shared Savings Program (MSSP) ACOs recently received their financial and quality results for Performance Year (PY) 2020 from CMS. These results are embargoed until further notice from the agency, but ACOs may share results internally and with participants. NAACOS is hosting a webinar on August 24 to walk through key factors affecting the results and participants will hear analysis and reactions from data experts and ACO leaders. It is anticipated that CMS will make public the program-wide 2020 results in the coming weeks, which is an important opportunity for ACOs and NAACOS to highlight the hard work of ACOs in improving quality and generating savings. We encourage ACOs to publicize positive performance results to demonstrate the value ACOs bring to patients and their communities. Please refer to our media toolkit on how to effectively tell your story.
CONGRESS TACKLES MULTIPLE MEASURES BEFORE AUGUST RECESS On August 10, the Senate cleared its infrastructure package by a vote of 69 to 30, sending the measure to the House for consideration. The bill includes several pay-fors related to healthcare, including provisions on drug rebates and discarded drugs. Speaker Pelosi has made clear that the House will not take up the infrastructure bill as a stand-alone measure. Instead, it plans to move the bill as a companion to a reconciliation bill that includes Democrat priority policies. Some moderate Democrats have called for the House to take up the infrastructure bill as a standalone. Also, this week, Majority Leader Schumer announced the Fiscal Year 2022 Budget Resolution, including instructions on reconciliation and proposals from committees of jurisdiction, including the Senate Finance Committee, which typically works on ACO-related legislation. NAACOS is working with Congress to emphasize the savings attributable to the Value in Health Care Act — an estimated $280M — and to identify opportunities to advance this priority legislation.
CMS FINALIZES POLICY ON PARTICIPATION IN BASIC TRACK GLIDE PATH Last week, CMS published the 2022 Inpatient Prospective Payment System (IPPS) Final Rule, which included a key provision for MSSP ACOs currently participating in the Pathways glide path. A fact sheet was also published by the agency. In this rule, CMS finalized a policy that allows MSSP ACOs in the Basic Track’s glide path to elect to remain in their current level of the glide path for PY 2022. NAACOS submitted comments earlier this summer on the proposed rule, requesting that CMS revise the proposed policy to not automatically advance ACOs to the level in which they would have been without this policy and instead to allow ACOs that elect to remain in their current level of participation to continue to the next level of the glide path after PY 2022. However, CMS finalized this policy without revision, which may cause ACOs that elect this freeze to have a dramatic jump in risk for PY 2023. NAACOS has developed a summary of the final rule for members.
ACCESS NAACOS PROPOSED 2022 MPFS RULE ANALYSIS, WEBINAR ON-DEMAND Take advantage of your membership by accessing our proposed 2022 Medicare Physician Fee Schedule (MPFS) analysis to review key proposals related to ACO quality assessments, patient assignment changes, application changes and more. You can also view our recent webinar, 2022 Proposed Medicare Physician Fee Schedule—What ACOs Need to Know, now available on-demand.
NAACOS TO REQUIRE VACCINATION TO ATTEND CONFERENCE IN-PERSON Join us in Washington, D.C., 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
CMS’s Lee Fleisher and National Quality Forum leader Dana Safran on the future of quality measurement
Keynote featuring Dr. Robert Pearl’s latest Uncaring with book give-away sponsored by Olio
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
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.
Welcome New ACO Members
EPC ACO LLC Austin, TX
Tandigm Health Conshohocken, PA
Gundersen Health Accountable Care Organization, LLC LaCrosse, WI
CMS ISSUED A SPATE OF MEDICARE PAYMENT RULES In recent weeks, CMS published other payment rules that ACOs should be aware of. The prospective payment system for skilled nursing facilities (SNFs) projects aggregate Medicare payments to SNFs will increase by $410 million or 1.2 percent in 2022 compared to 2021. The rule and factsheet are available.
Hospice payments will increase by 2.0 percent or $480 million in 2022 compared to 2021. This increase in driven entirely by the 2.7 percent increase in market basket. Hospices that fail to meet quality reporting requirements receive a 2-percentage point reduction to the annual market basket percentage increase for the year. The rule and factsheet are available.
Additionally, inpatient rehabilitation facilities will see payments increase by an estimated $130 million or 1.5 percent next year compared to last, according to CMS. The rule and factsheet are available. Finally, CMS estimates payments to inpatient psychiatric facilities will increase by 2.1 percent or $80 million in 2022. The rule and factsheet are available.
SDOH LEARNING COLLABORATIVE, FALL 2021 NAACOS and the Institute for Accountable Care (IAC) 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 must submit an application and space is limited. Additional details and a link to the application are available. Please contact us if you have any questions.
COMPLIANCE: MSSP THROUGH DCE AND THE TOOLS TO CHECK EVERY BOX 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 on 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 PY 2022. Register now and we’ll see you there!
VOLUNTEERS NEEDED ON EVIDENCE FOR ACO DECISION-MAKING IAC seeks ACO participants for an advisory group on research priorities in the areas of primary care, home-based services, and case management. This could include, for example, medical or non-medical home visits, testing different home-based staffing models, or primary care enhancements that address social and emotional issues for ACO beneficiaries. The goal of this one-time session is to determine ACO priorities and knowledge gaps. Results from the discussion will lead directly into a Patient-Centered Outcomes Research Institute (PCORI) grant proposal to be submitted this fall. Eligible participants include those who are knowledgeable about their ACO’s strategic priorities and areas where they would like more evidence to guide decision-making. This virtual session will last approximately 60 minutes and include IAC staff along with clinical experts from Massachusetts General Hospital. We are targeting the week of August 23 or 30 to convene the group. If interested in participating, please contact Jennifer Perloff at jperloff@institute4ac.org.
2020 MIPS PERFORMANCE FEEDBACK NOW AVAILABLE CMS has released Merit-Based Incentive Payment System (MIPS) performance feedback and final scores for PY 2020 (corresponding to 2022 payment adjustments). You can now view your MIPS performance feedback on the Quality Payment Program (QPP) website. CMS notes that as of August 5, ACOs now have the ability to manage their HCQIS Access Roles and Profile (HARP) account via the ACO-Management System (MS). Finally, if you believe an error has been made in the calculation of your MIPS score/payment adjustment factors, a targeted review can be requested via the QPP website through October 1, 2021.
DIRECT CONTRACTING ENTITIES BEGIN IMPLEMENTATION PERIOD On August 1, the Innovation Center launched the second Implementation Period (IP) for the GPDC Model. This IP is available to DCE accepted by the Innovation Center for participation beginning in the model’s second year (2022), including any DCE that was accepted for participation in 2021 but deferred as well as Next Generation ACOs that applied and were accepted following CMS’s decision to not further extend that model. During the IP, DCEs may participate in Voluntary Alignment but will not be participating in any of the model’s payment mechanisms, which go into effect during their first performance year of 2022.
CMS INNOVATION CENTER PUBLISHES BIANNUAL REPORT TO CONGRESS The CMS Innovation Center recently submitted its fifth Report to Congress, providing updates on its work conducted between October 2018 and September 2020. Over that time, the Innovation Center announced, tested, or issued rulemaking for 38 models and initiatives. These include the ACO Investment Model, which showed $526 million in gross Medicare savings over its first three years. It also includes the Next Generation ACO Model, which NAACOS is disappointed was not extended for another year. The report states nearly 38 million Americans are served by the MSSP and Innovation Center models, and more than 183,000 eligible clinicians received Advanced Alternative Payment Model Incentive Payment in 2020.
RECORDING FOR DIRECT CONTRACT LEARNING DISCUSSION AVAILABLE Thank you for all of those who joined us for this week’s Direct Contracting Learning Discussion. It is great to have participants share their feedback, questions and answers with others. After many requests, we have decided to start recording these discussions and sharing with those who may not be able to make join live. Future Learning Discussions will be found on our stand-alone Direct Contracting page and this week’s is now available. Stay tuned for information about or next Learning Discussion.
NAACOS SUPPORTS LEGISLATION THAT WAIVES CCM COST SHARING NAACOS was one of 12 organizations to pledge its support of the Seniors’ Chronic Care Management Improvement Act of 2021. This bill, introduced by Rep. Suzan DelBene (D-Wash.), would waive beneficiary cost-sharing under Medicare for chronic care management services (CCM), further opening the door for beneficiaries to benefit from care coordination and care management services. Typically, cost sharing for such services is less than $10, which creates a barrier for both providers and patients. As the letter states, only 684,000 patients out of 35 million Medicare beneficiaries with two or more chronic conditions benefitted from CCM services over the first two years.
NAACOS URGES NARROW MEDICARE COVERAGE FOR NEW ALZHEIMER’S DRUG NAACOS this week filed comments in response to CMS’ National Coverage Determination for Aduhelm (aducanumab), the first FDA-approved drug to treat Alzheimer’s Disease in more than 20 years. We share serious concerns that the expected costs of Aduhelm far outweigh its clinical benefits, which continue to be questioned by the medical research and treatment communities, and we urge CMS to implement a narrow national Medicare coverage determination until more scientific evaluations exist to support its efficacy. The initial list price of $56,000 per person for a year of treatment is five times the average ACO’s benchmark. While not necessarily part of CMS’ work on a National Coverage Determination, NAACOS also urges CMS to adjust ACO benchmarks to mitigate for Aduhelm’s cost, should the drug gain Medicare coverage.
NAACOS COMMENTS IN RESPONSE TO CONGRESSIONAL RFI ON PUBLIC OPTION LEGISLATION On July 30, NAACOS submitted comments to the House Energy and Commerce Committee and the Senate Health, Education, Labor, and Pensions (HELP) Committee in response to an RFI issued by the committees soliciting feedback on potential public option legislation. These comments highlight the importance of embedding value as a core component of any federally administered public option to ensure high quality, equitable care. Other recommendations in the comments include leveraging existing ACO models in the design of a public option and keeping a public option more like traditional Medicare. NAACOS continues to highlight ACOs as uniquely positioned to address health equity by stratifying data to target underserved populations and coordinate with social services to meet social needs and address social determinants. Past comments on the role of ACOs in addressing health equity can be found in NAACOS’ comments to a White House Office of Management and Budget (OMB) RFI and on the CMS IPPS Rule.
