HAPPY HOLIDAYS FROM YOUR FRIENDS AT NAACOS!! During this season, we take time to reflect upon the good things we have … like our engagement with you. We appreciate working with you throughout 2021, and the team at NAACOS wishes you peace, joy, and prosperity in the coming year. Thank you for your continued support and the great work you do every day. We would like to send our best wishes for the holidays and New Year. On behalf of the NAACOS board and staff, we look forward to working with you in the years to come!
NAACOS Resource Review: FAQS on MSSP Pathways to Success
New to MSSP’s Pathways to Success structure, have a change to your track for 2022, or just need a refresher? Don’t forget to review NAACOS’ updated resources on the most frequently asked questions around Pathways. The resource also provides invaluable links to several CMS documents, rule summaries, and recent updates. If you have additional questions that you cannot find, please contact us.
NEW NAACOS RESOURCE OUTLINES APP QUALITY REQUIREMENTS FOR ACOS CMS created the APM [Alternative Payment Model] Performance Pathway (APP) to better align quality measurement approaches for the Medicare Shared Savings Program (MSSP) with the Quality Payment Program (QPP) Merit-Based Incentive Payment System (MIPS). The APP includes notable differences in both quality reporting and scoring policies for MSSP, outlined in our new NAACOS resource. The changes include a new quality scoring approach for all MSSP ACOs as well as significant changes to how ACO quality scores contribute to ACO shared savings rates and loss rates, effective for all ACOs beginning with Performance Year (PY) 2021. Access this resource to learn more about your ACO’s quality reporting options for 2021 through 2025, as well as important changes to quality scoring that can have significant impact on your ACO and your shared savings.
CONGRESS PASSES DOC FIX BILL On December 10, the President signed the “Protecting Medicare and American Farmers from Sequester Cuts Act.” Prior to the bill’s passage for Calendar Year (CY) 2022, Medicare-enrolled physicians and certain non-physician practitioners faced a number of statutorily scheduled cuts, namely: a 3.75 percent payment cut due to budget neutrality; a 2 percent Medicare sequestration cut; and a 4 percent statutory “pay as you go” (PAYGO) budget neutrality sequester cut. The overall 9.75 percent cut has been a significant concern for providers, many of whom cite the significant financial strain during COVID-19 and the potential negative impact of the scheduled cuts. Under the new December 10 law, the 2 percent Medicare sequester cut will be delayed until March 31, 2022, followed by a reduction to 1 percent from April 1 to June 30, 2022; there is 3 percent one-year increase in the Medicare Physician Fee Schedule; and the PAYGO cuts are delayed through 2023. This presents several new deadlines for potential Congressional activity in the Spring of 2022, as well as the recently passed budget continuing resolution (CR), which expires on February 18, 2022.
Welcome New Associate ACO Member
Global Nephrology Solutions Tempe, AZ
TREAT YOURSELF TO BOOT CAMP OR CONFERENCE REGISTRATION FOR CHRISTMAS! Winter Boot Camp February 7–8, 2022 Orlando Airport Marriott Lakeside
NAACOS Winter 2022 Boot Camp provides expert insight into the core competencies for ACOs and DCEs. Boot camp faculty will present essential resources and policy updates as well as the basics on successful care management and resource allocation. The boot camp is a full two days this year (rather than a day and a half) and is being held in person only. A detailed schedule and agenda are available! Boot camps are not open to business partners. Space is limited to 110 people so Register Now!
Spring Conference April 27–29, 2022 Hilton Baltimore Inner Harbor
Hear from leading ACO experts and CMS officials sharing timely and essential information for ACOs at the Spring 2022 Conference. Register before March 4 for the in-person conference and receive a discount of $300 per person. Can’t attend in person? Register for our live webcast before March 4 and receive a discount of $100 per person. We are offering group rates for both the in-person and virtual conference. To register at the group rate, please contact Emily Perron. The Spring 2022 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. Reserve your space today!
DEMOCRATS ADVOCATE FOR BUILD BACK BETTER Senate Majority Leader Chuck Schumer (D-NY) has indicated that the Build Back Better (BBB) Bill will pass by the end of 2023, but its chances for advancement in the Senate are complicated by continued negotiations with Senator Joe Manchin (D-WV) as well as concerns over the true cost of the legislation over time. On December 10, the Congressional Budget Office released a new analysis and score for the measure estimating a $3 trillion cost over a 10 year window. This number far exceeds prior estimates, which were time limited, and Senator Manchin’s “line in the sand” with respect to overall cost for the bill. Over the weekend the Senate Finance and Health, Education, Labor and Pensions (HELP) Committees released revised BBB text for a number of health care related items, including the proposed Medicare hearing benefit, drug negotiation provisions, and hospital matters. The Senate Parliamentarian is also reviewing provisions for potential disqualification under the Byrd Rule, which precludes provisions extraneous to the budget from consideration under the reconciliation process—a process which only requires a simple majority in the Senate and through which the BBB would proceed if it advances. NAACOS continues to advocate for the inclusion of key issues in this package, such as policies to address the rural glitch and the 2023 expiration of the Advanced APM 5 percent bonus.
CMMI RELEASES 2022 GPDC PARTICIPATION AGREEMENTS CMS recently released the 2022 Participation Agreements (PAs) for both 2021 and 2022 DCEs. As expected, the changes are minimal and mostly non-substantive in nature. The revisions incorporate the mid-year amendments issued earlier this year. NAACOS believes the Center for Medicare and Medicaid Innovation (CMMI) will announce more significant program changes late Spring 2022 to take effect in the 2023 model year.
Copies of the clean and redline version of the 2022 PAs are available on NAACOS’ Direct Contracting page. A full list of changes in the PA is available in this NAACOS resource. A few key changes from the PA include:
Allowing a DCE to select to participate in the model as a New Entrant DCE or Standard DCE after the DCE’s first performance year if the DCE is a High Needs Population DCE.
Allow the DCE to enter into provider contracts and cost-sharing support arrangements at the entity level.
Allow DCEs to update core service area during a performance year. DCEs will have at least one opportunity to add counties to the DCE’s core service area during a given performance year to account for the addition of new physical office locations for either newly added DC participant providers or existing DC participant providers during the performance year.
Update the quality measures. Specifically, DCEs must report Consumer Assessment of Healthcare Providers and Systems (CAHPS) Survey measures beginning in 2022. For 2022, CAHPS will be “pay for reporting” for all DCEs.
Update the lookback period if CMS determines that experience from CY 2021 is not sufficiently predictive for PY 2022 when calculating the Primary Care Capitation (PCC) Payment, the Advanced Payment Option (APO) Payment Amount, and the Total Care Capitation (TCC) Payment.
Welcome New Business Partners
Signify Health We help organizations become value-based; we enable to shift to value. Our leading healthcare platform combines technology, analytics and networks to power and create value-based payment programs, driving better outcomes and experiences. signifyhealth.com
MCG Health MCG Health, part of the Hearst Health network, helps healthcare organizations proactively and efficiently manage the health and well-being of their patient populations. MCG solutions can be integrated into virtually any electronic health record (EHR) platform or medical management system. mcg.com
MIPS HARDSHIP EXCEPTIONS AND ACOS MIPS provides an exception for Extreme and Uncontrollable Circumstances for certain clinicians and groups. APM Entities, can request this exception through December 31, 2021. For ACOs, at least 75 percent of the MIPS eligible clinicians in the APM Entity would need to qualify for reweighting in the Promoting Interoperability performance category to be eligible to apply for this exception. If approved, the exception would apply for the Promoting Interoperability performance category only for ACOs subject to MIPS. This does not affect an ACO’s MSSP quality score, but rather focuses solely on MIPS scores for those ACOs subject to MIPS. Applications can be submitted on the QPP website and CMS will notify applicants via email whether their request are approved or denied.
NAACOS PUBLISHES CASE STUDIES ON ACO HEALTH EQUITY EFFORTS Recently, NAACOS published a series of documents which describe ACO efforts in linking clinical care and social services to reduce health inequities and address the social needs of their patient populations. The documents include a high-level overview as well as three individual case studies that highlight the work of innovative ACOs that have developed unique solutions to meet the needs of their patients. This work can be found on NAACOS’ health equity page, which was launched earlier this year to provide a central space for information and resources to guide ACOs working to improve health equity and/or address social determinants of health for their patients. This webpage includes NAACOS letters and resources, as well as external research and common definitions. If you think you have a resource that should be included on this page, email Alyssa Neumann to review for inclusion.
2022 NAACOS LEADERS IN QUALITY EXCELLENCE The NAACOS Leaders in Quality Excellence Awards have been established to recognize the outstanding efforts among ACOs working to improve the quality and safety of patient care and advance population health goals. At this time, we are inviting NAACOS ACO member organizations to submit an entry for a quality project recently taken on by the ACO to improve the quality of care provided to its patients. NAACOS will recognize the top three submissions, selected by the NAACOS Quality Committee, at our Spring 2022 Conference to showcase the exemplary efforts in quality improvement among our members and to disseminate best practices. NAACOS invites ACOs to submit projects that demonstrate innovative quality improvement strategies used by your ACO to improve patient health outcomes. Examples of projects could include initiatives implemented as part of the ACO’s COVID-19 response, programs that address disparities in health outcomes, or other innovative quality improvement strategies used by your ACO to improve patient health outcomes. To be considered, entries must be submitted by February 4, 2022. Please limit entries to one submission per ACO. More information on the award criteria and submissions process are included below. Should you have any questions, please contact us at advocacy@naacos.com. We are pleased to open the submissions process and look forward to learning more about the important quality improvement efforts our members have been engaged in!
CMS HOSTS ROUNDTABLE ON HEALTH EQUITY STRATEGY Last week, CMS hosted a roundtable on priorities for CMMI to achieve its health equity strategy goals, as published in the recent strategy refresh paper, with leaders from various stakeholder groups contributing thoughts. Speakers were asked to discuss what CMMI should focus on to reduce and eliminate health inequities when building models, how to improve self-reported data collection, and how to enable safety net providers to overcome obstacles to participating in accountable care models. Many addressed the need for high-quality, standardized data to guide this work. Speakers also suggested leveraging the ACO model to address health equity, specifically suggesting upfront funding and adjusted financial benchmarks, which NAACOS has recommended. NAACOS applauds the work of CMMI to embed health equity into new and existing models, and we will continue to work collaboratively to support ACOs in their efforts to improve health equity. More information on the Innovation Center’s strategic direction and future events is available.
REMINDER: HOW BENCHMARKS ARE ADJUSTED DURING THE COVID-19 PHE For ACOs joining MSSP in 2022 or renewing an agreement for 2022, NAACOS wanted to remind ACOs of the various adjustments CMS makes to benchmarks and other financial calculations, especially with the COVID-19 public health emergency (PHE) continuing into the new year. According to CMS guidance on PHE-related adjustments, the agency will remove all of a beneficiary’s Part A and B expenditures for affected months triggered by an inpatient episode of COVID-19 care. This includes performance year expenditures, future benchmarks, updates to the historical benchmarks (i.e., trend rates), and revenue calculations for determining loss sharing limits for certain ACOs.
Despite NAACOS advocacy, CMS is continuing to use 2019–2021 as the baseline years for ACOs starting new agreements next year. Given the on-going pandemic and dramatic drop in utilization as a result, NAACOS asked CMS to give ACOs the option to select pre-pandemic years in lieu of the normal 2019–2021 to provide a more realistic expectation of spending. But CMS has yet to accept our request.
As a reminder, CMS will continue to waive shared losses for at-risk ACOs for the duration of the PHE, which has been in effect for all of 2020 and 2021. There are a myriad of other PHE-related flexibilities for ACOs, which NAACOS summarizes. The PHE will last into 2022, but it’s unclear to us when HHS will stop renewing it. The department hasn’t given a clear outline of what will trigger its expiration or when that may happen.
CMMI TO MAKE MORE NEXT GEN DATA AVAILABLE Following NAACOS advocacy, the CMMI has made available data from 2019 on the Next Generation (Next Gen) ACO Model that will allow researchers to conduct more detailed analysis on the program. This data, contained in what’s called Research Identifiable Files, contains enrollment data for Next Gen-assigned beneficiaries and participating providers will allow independent analysis of the program. This includes counterfactual studies of Next Gen’s savings. In August, CMS released Research Identifiable Files from Next Gen’s first three years. NAACOS is very pleased to see more transparency in data released on CMMI programs and will continue to advocate for greater transparency going forward.
