NAACOS LETTER TO CMMI URGES CHANGES TO DIRECT CONTRACTING NAACOS recently sent Brad Smith, the new director of the Center for Medicare & Medicaid Innovation (CMMI), a letter stating our concerns and offering several suggestions about the forthcoming Direct Contracting Model. Among the issues raised are the need for remaining program details as soon as possible; minimizing discount levels; addressing overlap of different Direct Contracting Entity (DCE) types by allowing Participant Providers to dually participate in both a High Needs and Standard DCE; making available the algorithm used to identify high-needs patients; increasing the shared savings rate for the Professional Option to 75 percent; aligning application timelines and participation-decision deadlines between Direct Contracting and other ACO models, among others items. NAACOS also issued a press release on the letter. We hope this letter will help launch additional conversations about the future of Direct Contracting and what’s needed for ACOs to succeed.
CMS MAKES ACO-18 PAY FOR REPORTING IN 2019 In response to NAACOS concerns raised regarding changes to the ACO-18 quality measure (Screening for Depression and Follow-Up Plan/PREV-12), CMS has retroactively made the measure pay-for-reporting in 2019 for both Medicare Shared Savings Program (MSSP) and Next Generation ACOs. Additionally, CMS will accept 2018 specification documentation to satisfy Quality Measures Validation (QMV) audits. The modifications to the measure for 2019 removed codes that recognized the rescreening of a patient using an additional standardized depression screening tool as a means of meeting performance criteria for implementing an appropriate follow-up plan.
CJR PROPOSED RULE WOULD EXTEND MODEL THROUGH 2023 CMS recently released a proposed rule revising certain aspects of the Comprehensive Care for Joint Replacement (CJR) Model and extending the model for an additional three years through December 31, 2023, for certain participants. Proposed changes include altering episode of care definitions, target price calculations, the reconciliation process, beneficiary notice requirements, and the appeals process. The proposed rule also would remove the 50 percent cap on gainsharing payments for certain recipients in performance years six through eight. The rule also includes a solicitation of comments regarding how CMMI may design a future bundled payment model focused on lower extremity joint replacements (LEJR) performed in the Ambulatory Surgical Center (ASC) setting.
ACO COMPLIANCE MANUAL: NAACOS HAS DONE THE LEGWORK FOR YOU! Good news! NAACOS offers a Pathways-updated compliance manual to MSSP ACOs. The manual includes a robust set of policies and procedures that ACOs can customize to meet their own needs. Why should an ACO purchase the manual? ACOs are required to meet many state and federal regulatory requirements, including health care fraud and abuse laws, privacy requirements, and the specific requirements of CMS. The manual is a necessary tool designed to provide template policies that help ACO leaders to determine the best next steps for their ACOs and to implement procedures to ensure compliance with program requirements. A 12-month subscription to the manual is available and includes access to any updates made during the subscription term. If you are a current subscriber, login to check out the newly updated version.
ACO QUALITY AND PI REPORTING DEADLINES APPROACH The ACO quality reporting submission deadline is fast approaching. CMS will automatically accept the data entered in the Quality Payment Program (QPP) website as of Tuesday, March 31, 2020, at 8:00 p.m. ET. This information will be considered your final submission. As a reminder, you must have an appropriate user role associated with your organization with a Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) User ID and password to complete the submission process.
Additionally, for ACOs subject to MIPS, the deadline for clinician practices and individual eligible clinicians (ECs) to submit their Promoting Interoperability (PI) data is also Tuesday, March 31, 2020, at 8:00 p.m. ET. Practices and clinicians will report and attest to PI data also via the Quality Payment Program (QPP) website. Hospitals and Medicaid Eligible Professionals (EPs) also report PI data under separate hospital PI rules and requirements; the acute hospital, Critical Access Hospital, and Medicaid PI reporting deadline to submit is March 2, 2020. More information on the hospital and Medicaid PI requirements are available.
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VISIT OUR ‘TAKE ACTION’ PAGE As Congress continues to debate important healthcare issues, NAACOS needs your help to ensure ACO-specific issues can stay on lawmakers’ agenda. Please take a few minutes to write your elected representatives on a new issue NAACOS is currently working on. Ask your Member of Congress to support legislation in both the House and Senate that corrects an unintended flaw in the current MSSP benchmarking methodology by removing an ACO’s assigned beneficiaries from the regional reference population. Currently, CMS includes an ACO’s own beneficiaries in the regional adjustment, which nullifies that adjustment for ACOs who have lower historic spending than their regional competitors. NAACOS continues to ask Congress to remove patient cost sharing for Medicare chronic care management codes and to make it easier to share patients’ substance abuse treatment records. Visit our Take Action page to write a letter to your congressmen. Just remember to personalize the letters we’ve drafted to help get your started.
CAN’T ATTEND THE CONFERENCE IN PERSON? WATCH IT LIVE! ACOs are positioned at the intersection of value-based payments, population health, care coordination, innovation, transformation, and collaborations among Medicare, Medicaid and commercial payers. ACOs and other models focusing on population health can create a future where quality is better, costs are lower, and patients are engaged. This Spring join us for a two-day look into the tools and strategies for achieving this future. The conference will be packed with critical insights, strategies and perspectives from national ACO experts, plus case studies, best practices, valuable data and lessons learned from leading ACOs around the country. Our live webcast enables you to watch our conferences from anywhere you have an internet connection. Join the live webcast on April 2–3 and watch the entire conference!
You will be given log in information prior to the conference start date. The live webcasts are presented at the same time as the physical event and are not just video replays. ALL individuals regardless of membership status are eligible to purchase the live webcasts of the conference including non-business partner vendors. ACO Members are $525; Business Partners are $725; and all non-members are $925.
NAACOS CO-HOSTS CONGRESSIONAL BRIEFING NAACOS and our coalition partners will join the Congressional Health Care Innovation Caucus on Friday, February 28, to participate in a healthcare payment model boot camp for Congressional staff. The boot camp will educate staff about how innovative healthcare providers are successfully delivering improved patient care at lower costs through two-sided risk-based payment models like bundled payment arrangements and ACOs. Staff will have the opportunity to hear directly from leading providers and health systems on the barriers they have overcome transitioning to alternative payment models. This Congressional briefing provides NAACOS with a platform to encourage Congressional action on a number of reforms to ensure the success of value-based payment initiatives.
CMS CLARIFIES MSSP’S TELEHEALTH USE In the most recent ACO Spotlight, CMS shares additional insight on how certain ACOs can use telehealth, specifically what services are “inappropriate to be furnished in the home.” Starting January 1, 2020, MSSP ACOs under two-sided risk and using prospective assignment may provide telehealth services to prospectively assigned beneficiaries, regardless of Medicare’s restrictive telehealth coverage rules. Following questions from NAACOS on what CMS considers inappropriate, the agency clarified that Current Procedural Terminology (CPT) codes G0406, G0407, G0408, G0425, G0426, and G0427 are “inappropriate to furnish in the home setting because they are specific to an inpatient setting. Also, telehealth G-codes specifically created for Next Generation ACOs do not apply to Shared Savings Program ACOs. Additional information on MSSP’s use of ACOs can be found in this CMS fact sheet.
CMS POSTS ACO VIDEO AND CASE STUDIES CMS recently posted a new video of highlights from interviews with Next Generation ACO and End-Stage Renal Disease Seamless Care Organization (ESCO) representatives. The video aims to explain what an ACO is and how ACOs work to improve care for Medicare beneficiaries. The video is available. CMS also highlights three case studies describing ESCO and ACO efforts and lessons learned:
