FINAL DAY FOR EARLY REGISTRATION RATE IS FRIDAY, FEBRUARY 14 NAACOS has extended the early registration deadline for the Spring 2020 Conference through Valentine’s Day, just because we love you all so much! Register before the end of the day to get the $300 discount per person off the standard rate.
Join your ACO peers and CMS leaders Amy Bassano, Pauline Lapin, and John Pilotte on April 1–3 at the Hilton Baltimore Inner Harbor for a conference packed with critical insights, strategies and perspectives from national experts, plus case studies, best practices, valuable data and lessons learned from leading ACOs around the country. NAACOS conferences are the only events organized exclusively by ACOs. Visit our website for more information on the agenda, registration, exhibit and sponsor opportunities, and hotel details.
PRESIDENT’S BUDGET LANDS ON CAPITOL HILL The White House released President Trump’s Fiscal Year (FY) 2021 budget request on Monday. The Health and Human Services (HHS) budget is available. Administration officials, including HHS Secretary Alex Azar, have been on Capitol Hill this week testifying about the request which includes a 9 percent cut to HHS. It also includes approximately $770 billion in mandatory funding reductions for health programs over the next 10 years.
As in past years, the budget proposes site neutral payments for hospitals. It also includes several proposals that advance HHS’s efforts to shift toward paying for patient outcomes in Medicare and a few provisions that would directly affect ACOs. Specifically, the budget proposes allowing the Secretary to enhance the role of non-physician providers in ACO assignment. ACOs would also be allowed to apply incentive payments on a subset of primary care services, a change supported by NAACOS. The budget also proposes that the 5 percent bonus for clinicians in Advanced Alternative Payment Models (APMs) would be based only on physician fee schedule revenues received through the APM in which they participate, rather than basing the bonus on all Medicare physician fee schedule payments. This would decrease the amount of the Advanced APM bonus for specific clinicians but would avoid the all-or-nothing approach currently in place that requires clinicians to meet Qualifying APM Participant (QP) thresholds. Lastly, the budget predicts that the changes from the Pathways to Success rule will save Medicare an estimated $2.9 billion over 10 years.
More details on these budget proposals will be released by the Administration in the near future. It’s important to note that while budget requests reflect the Administration’s policy priorities, they are non-binding. Spending packages must be approved by Congress. Lawmakers are expected to begin working on FY 2021 spending bills in the next few weeks. Final spending packages will likely be approved after the November election.
REDUCING THE USE OF LOW VALUE CARE IN ACOS The Institute for Accountable Care (IAC) is looking for ACOs who are interested in reducing the use of low value care to join an advisory group to help plan a future study or learning collaborative in this area. Common examples of low value care include unneeded imaging, excess use of colonoscopy for cancer screening or PSA testing for prostate cancer. Experts from the ABIM Foundation and Kaiser Permanente/MacColl Institutes have found that you need to engage multiple stakeholder to make a dent in these and other common practices.
IAC is seeking 6-to-10 ACOs to participate in the project with four meetings between now and the end of summer. The planning committee will work together to identify important types of low value care to focus on, strategies to reduce the use of these services, and important learning objectives for the ACO community. Participants will have an opportunity to participate in a survey of high-value culture in their organizations. If you are interested in more information, please reach out to Leslie Valera at lzv@institute4ac.org.
NAACOS URGES CMS TO REMOVE BENEFICIARY NOTIFICATION NAACOS recently sent a letter to CMS urging the agency to remove the beneficiary notification requirement included in the recent Pathways to Success regulation. In the letter, NAACOS notes the additional regulatory burden caused by the requirement, which intends to inform patients but instead is a source of confusion. NAACOS has repeatedly called for CMS to remove this burdensome notification requirement.
Welcome New ACO Members
Baycare Physician Partners Clearwater, FL
Excel Health ACO Spring, TX
Luminis Health Annapolis, MD
PROMOTING INTEROPERABILITY DEADLINE IS MARCH 2 As a reminder, the deadline to submit 2019 data for Promoting Interoperability (PI) is March 2, 2020. ACOs who are subject to the Merit-Based Incentive Payment System (MIPS) should remind practices to submit PI data prior to the deadline. CMS will aggregate practice and clinician level PI data to calculate a weighted average PI score for the ACO. For more information, access our ACO Guide to MACRA 2019 Edition.
CHECKING YOUR ACO’S QP STATUS: NEW FAQ NAACOS has received several member questions regarding how certain eligible clinicians (ECs) within the ACO can be designated with different QP status. In order to respond to these questions and clarify how QP snapshot dates inform MIPS/QP status, NAACOS reached out to CMS for more guidance and created a new FAQ to explain this issue. Access our ACO Guide to MACRA to learn more.
The CMS QPP Portal shows some ECs having QP status while others have MIPS status within our same ACO. How is that possible? I thought the QP status was determined at the ACO level and not the individual clinician level?
For purposes of determining QP status vs MIPS status, CMS makes three determinations throughout the performance year at each of the three snapshot dates (March 31, June 30, and August 31). The ACO is evaluated at the ACO entity level for each snapshot date. CMS specifically looks at the group of ECs participating in an APM Entity as identified by a combination of the APM identifier, APM Entity identifier, Taxpayer Identification Number (TIN), and National Provider Identifier (NPI).
Because of the numerous QP evaluations, there can be instances where some clinicians receive a different status than others within the same ACO. As an example, if an ACO is determined to have met QP status on snapshot date 1, all of the ECs included in that evaluation receive the QP status. However, if the ACO does not meet QP status on snapshot date 2, if there were ECs added to participant TINs from snapshot date 1 to snapshot date 2, the new ECs would not obtain QP status given the fact that the ACO did not meet the QP threshold on snapshot date 2. However, if the ACO goes on to meet the QP threshold on snapshot date 3, then the new ECs would at that time be given QP status. If the ACO did not meet the QP threshold on snapshot date 3 in this example, then the new ECs would not obtain QP status even though the rest of the ACO does retain the QP status it achieved during snapshot date 1.
NEW LEGISLATION PLACES ‘GUARDRAILS’ ON CMS INNOVATION CENTER A new bipartisan bill in the House of Representatives seeks to strengthen the Center for Medicare and Medicaid Innovation (Innovation Center) from future political attacks by limiting the scope of its power. The Strengthening Innovation in Medicare and Medicaid Act (H.R. 5741) has 10 sections, including ones that would provide congressional oversight of the Innovation Center’s work and limit the scope and duration of new models. NAACOS is pleased to see language included that would increase the transparency of the Innovation Center’s work by increasing public input on model development and program updates and would force HHS to address the overlap of different payment models. Lawmakers have expressed concern with the Innovation Center’s work because it can unilaterally enact sweeping changes and large demonstrations without congressional approval. NAACOS supports aspects of this bill and is working to further refine the bill before Congress possibly takes action on it later this year.
2020 ACO PUBLIC REPORTING DEADLINE EXTENDED TO FEBRUARY 14 CMS has given a one-week extension to complete updates to ACO public reporting webpages for Performance Year (PY) 2020; the new deadline is February 14. CMS instructs ACOs to populate the template using data from the ACO-MS and ACO data per the instructions included with the sample Public Reporting Template. To access the template, search for “Public Reporting” under the resources section of the ACO portal.
Welcome New Business Partners
NavCare NavCare offers 30+ years of post-acute experience in senior living, home health and chronic care management with a track record of reducing readmissions, lowering the cost of care and navigating patients to a care model that meets them where they are. navcare.com
DIRECT CONTRACTING TOWN HALL SET FOR FEBRUARY 20 NAACOS will host a Town Hall-style meeting on Direct Contracting on February 20 at 2:00 pm ET. This will be a chance to ask questions of NAACOS staff and other ACOs, give feedback on NAACOS’s list of advocacy ideas, bring topics you need clarification on to the Innovation Center, and discuss the upcoming Implementation Period and its application deadline. Register today and bring your ideas!
This Town Hall will provide more of a peer-to-peer discussion opportunity, which is in contrast to our educational webinars on Direct Contracting that have more in-depth presentations by speakers. Those webinars are available on-demand and are as follows:
Understanding the Direct Contracting Model, available.
Navigating the Model Matrix 101, available. This webinar reviews Key Alternative Payment Models under development by the CMS Innovation Center and discusses how models overlap with ACOs.
Navigating the Model Matrix 201, available. This webinar provides a more in-depth look at new Medicare APMs to help ACOs evaluate new models and develop participation strategies.
ACO 2019 QUALITY REPORTING DEADLINE IS MARCH 31 The PY 2019 quality data submission period for ACOs will take place from January 2, 2020, at 10:00 am ET closing March 31, 2020, at 8:00 pm ET. ACOs submit quality data using the CMS Web Interface. For ACOs subject to MIPS, CMS also uses this quality data to assess quality performance for that program.
CMS has now delivered a CMS Web Interface Beneficiary Sample Excel file via the Managed File Transfer (MFT) mailbox to each ACO’s quality reporting sample for PY 2019. This file will be available in the MFT mailbox for 30 days from the delivery date. ACOs will need to access this file through the binary directory. If you need additional guidance regarding downloading binary files, please reference the two MFT manuals in the ACO and ACO-OS (ACO-Operational System) Data Exchange User Guide, Version 8 (V8) available in the resources section of the ACO-MS. Each person associated with an ACO who needs to access the CMS Web Interface must have his or her own Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account with the appropriate role. This will allow the users to download their ACO’s Beneficiary Samples and submit CMS Web Interface data. Detailed instructions for creating a HARP account and requesting a role are available in the QPP Access User Guide, available in the QPP Resource Library. CMS instructs ACOs to contact the QPP Help Desk with any questions regarding this process at QPP@cms.hhs.gov or 1-866-288-8292. CMS has also posted a demo video.
More information on ACO quality reporting is available in our new ACO Quality Reporting Guide or access our on-demand webinar for tips and best practices.
TAKE ADVANTAGE OF NAACOS LISTSERVS Don’t forget to sign up to receive posts from and participate in the different listservs NAACOS offers. We offer three listservs, including our latest one specifically about Direct Contracting. As a member, you have access to this exclusive opportunity to engage in dialogue with other ACOs on areas of key interest. But you must sign up to be able to post, respond to or receive listserv messages. Questions related to Direct Contracting can also be directed to NAACOS staff at directcontracting@naacos.com.
MEDICARE ADVANTAGE REGULATION RELEASED CMS proposed last week to increase baseline Medicare Advantage (MA) payment rates for 2021 by 0.93 percent and allow Medicare beneficiaries with end-stage renal disease to enroll in MA plans starting next year. Relatedly, CMS proposes to move organ acquisition costs for kidney transplants from MA benchmarks to fee-for-service. If finalized, CMS would allow MA plans to count telehealth as contributing toward network adequacy standards in select specialties, including psychiatry, neurology and cardiology, and weigh patient experience and complaints and access measures more heavily in start ratings.
The changes were proposed in CMS’s annual Advance Notice governing MA and Part D plans. NAACOS continues to monitor changes in the MA space. The full proposed rule, fact sheet and press release are all online. Last month, CMS proposed changes to MA’s risk adjustment methodology.
MEDICAL SURPRISE BILLING LEGISLATION MOVES FORWARD The House Committees on Ways and Means and Education and Labor approved competing surprise medical billing proposals this week. The Education and Labor proposal includes a benchmark payment similar to legislation approved last year by the House Energy and Commerce and Senate Health, Education, Labor, and Pensions (HELP) Committees. The Ways and Means Committee would only use negotiation and arbitration to determine payments. Congressional leaders are working to negotiate an agreement that can be included in a May healthcare package.
