NAACOS Newsletter for Members and Partners January 17 2019
Table of Contents
NAACOS Releases New Resources on Final Pathways to Success RuleCMS Sets February 19 Deadline to Apply for MSSP
2018 Quality Reporting Deadlines Approach; 2019 Quality Measure Docs Released
New CMS Guidance Offers Clarity on SNF Waivers, Beneficiary Incentive Program
Congressional Leaders Want Answers on CMMI’s Work
Reissued High-Low Revenue Reports Coming Soon
HHS Outlines Process for Approving New Payment Models
Agenda for Spring Conference Now Available
Boot Camp for Risk-Takers: February 11-12, Orlando
QPP Website Updated to Include Third Snapshot Data for APM Entities
CMS Releases Details on New CEHRT Attestation Req. Effective in 2019
Seeking Members for a New Initiative to Improve Care for HNHC Patients
NAACOS RELEASES NEW RESOURCES ON FINAL PATHWAYS TO SUCCESS RULE
NAACOS has developed an in-depth analysis of the final Pathways to Success Rule. This analysis reviews key changes in the final rule and critical application considerations for participation in the Medicare Shared Savings Program (MSSP) in 2019 and beyond. In addition to this detailed analysis, NAACOS has developed a Frequently Asked Questions resource on the final rule, which we will update as we continue to get clarification on certain policies and details from CMS. As a reminder, NAACOS also recently held a webinar for members walking through the changes in this significant regulation, available on-demand. For questions on the new Pathways to Success program structure, please email us at [email protected].
CMS SETS FEBRUARY 19 DEADLINE TO APPLY FOR MSSP
The deadline to submit a non-binding Notice of Intent to Apply is January 18, 2019, for ACOs interested in starting new contracts beginning July 1, 2019, under the new program structure created by the final Pathways to Success Rule. The application deadline is February 19, 2019. NAACOS has been critical of this condensed application timeframe and will advocate for CMS to extend these deadlines. As a reminder, ACOs whose agreements did not expire on December 31, 2018, have the option to complete their existing agreements under existing program rules. CMS anticipates resuming the typical annual application cycle later this year for agreements starting on January 1, 2020, and in subsequent years. CMS continues to issue guidance and resources for ACOs, and NAACOS continues to monitor for updates. The agency has so far released the application toolkit, Request for Information (RFI) response actions and deadlines, a sample participation agreement, and instructions for completing a data use agreement. CMS also released guidance on ACO participant lists and participant agreements and repayment mechanisms.
Finally, CMS has also released guidance on the steps ACOs can take during their application process to prove they can repay shared losses in two-sided models. The 38-page document details the different repayment mechanism arrangements, including funds placed in escrow established with an insured institution, evidence of a line of credit at an insured institution, or a surety bond issued by a company included on the U.S. Department of Treasury’s list of certified companies. For ACOs entering Basic Level C, D or E or Enhanced Track under the Pathways program, ACOs must show they can repay the lesser of either 2 percent of the total Medicare Parts A and B fee-for-service revenue of ACO participants or 1 percent of the total per capita Medicare Parts A and B fee-for-service expenditures for assigned beneficiaries. It is possible that shared losses could either be more or less than the repayment mechanism amount. For questions on the new Pathways to Success program structure, please email us at [email protected].
2018 QUALITY REPORTING DEADLINES APPROACH; 2019 QUALITY MEASURE DOCUMENTS RELEASED
CMS recently noted in an ACO Spotlight article that ACO quality reporting for the 2018 performance year will take place from January 22 through March 22, 2019, at 7:59 pm ET. CMS notes the Web Interface test period will be available from January 7 through January 18, 2019.
During the test period, ACOs can log into the CMS Web Interface, download beneficiary samples, practice uploading data and use the Web Interface Application Programming Interface (API) prior to the start of the actual submission period. Note that the Web Interface will be unavailable between January 19 and January 21. CMS has provided ACOs with a number of webinars and instructional guides to assist ACOs in quality reporting; these resources are available in the MSSP ACO Portal.
CMS also posted 2019 Measure Information Forms (MIFs) for ACO quality measures, which describe in detail each administrative and claims-based quality measure that ACOs will be evaluated on for 2019. CMS also posted an updated 2019 Quality Measure Benchmarks document. Please note this information is applicable only to the 2019 performance year.
Welcome New ACO MemberBuena Vida y Salud, LLC |
NEW CMS GUIDANCE OFFERS CLARITY ON SNF WAVIERS, BENEFICIARY INCENTIVE PROGRAM
ACOs interested in utilizing either the new beneficiary incentive program or a waiver of the Skilled Nursing Facility (SNF) 3-Day Rule have more guidance from CMS. The SNF Waiver’s 24-page guidance offers insight about eligibility, applying, compliance, communication requirements, and other areas of concern needed to participate. CMS has also published an application checklist for the waiver.
CMS is also outlining the application process to participate in the beneficiary incentive program starting July 1, 2019. The benefit allows ACOs to provide incentive payments of up to $20 to eligible beneficiaries who receive qualifying primary care services. ACOs must outline the form of payment, how they would notify participants and assigned beneficiaries about the incentive program, how and when they would distribute payments, and how they would track whether a beneficiary is entitled to receive an incentive payment, among other steps.
CONGRESSIONAL LEADERS WANT ANSWERS ON CMMI’S WORK
Leaders of a key House committee want more transparency in the work of the Center for Medicare and Medicaid Innovation (CMMI), calling for “more sunshine” while developing new alternative payment models. New Ways and Means Committee Chair Richard Neal, a Democrat, and Ranking Republican Kevin Brady wrote CMS Administrator Seema Verma last week expressing concern that Congress and stakeholders are too often shut out of the model-development process. The lawmakers ask for more information on CMMI’s work, timelines for finishing, and ways to involve stakeholders, patients, and Congress more in its work. NAACOS has recently called for CMMI to release more information on the future of the Next Generation Model ACO program, which is set to sunset at the end of next year.
REISSUED HIGH-LOW REVENUE REPORTS COMING SOON
Given the significance of the new high-low revenue distinction, NAACOS will soon be sending individual ACOs’ updated reports indicating their high or low revenue status based on CMS’s finalized threshold established in the Pathways to Success rule. The designation, which is based the ratio of an ACOs’ participant revenue compared to its benchmark, determines program specifics such as how much time an ACO can spend in the Basic Track, which offers lower levels of risk. To better understand the potential impact of the policy, NAACOS used the NAACOS ACO Data Warehouse to simulate high- and low-revenue designations for all ACOs participating in the MSSP in 2016 (the last full year of data in the warehouse). The analysis will be based on 2016 claims data and on an ACO’s configuration for that year. If an ACO adds or drops ACO participant providers, their designation could change. CMS’s calculations will be based on the most recent calendar year for which 12 months of data are available. The analysis will soon be available in your NAACOS web portal, the same location as your ACO’s B-CAPA reports – https://reports.naacos.com. Report access will be granted to each ACO’s primary contact. For technical questions contact [email protected] and all other question contact Teresa Litton, [email protected].
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HHS OUTLINES PROCESS FOR APPROVING NEW PAYMENT MODELS
A new HHS document aims to help clarify how the department is using recommendations from the Physician-Focused Payment Model Technical Advisory Committee (PTAC). The PTAC was authorized under the Medicare Access and CHIP Reauthorization Act (MACRA) and is a panel of outside experts that deliberate on and recommend alternative payment models for HHS’s consideration. The document released last week outlines HHS’s four areas of focus for value-based transformation: (1) patients as consumers, (2) providers as accountable patient navigators, (3) payment for outcomes, and (4) prevention of disease before it occurs. At its September 2018 meeting, members of the PTAC expressed displeasure that none of the models it had recommended HHS work on were yet approved. In addition, last week the PTAC issued an updated version of its proposal submission instructions document, which serves as the official guidelines for submission of proposals to the PTAC.
AGENDA FOR SPRING CONFERENCE NOW AVAILABLE
The NAACOS Spring 2019 conference will be our biggest event to date with more than 700 leaders in accountable care. Join us on April 24–26 at the Hilton Baltimore for presentations by ACO experts, insight into the new rule from CMS officials, and peer-to-peer sharing of best practices. The conference program — featuring four plenaries, 14 breakouts, peer exchanges, and lots of networking — is now available. Register today and save $300!
BOOT CAMP FOR RISK-TAKERS: FEBRUARY 11-12, ORLANDO
CMS’s final rule on the MSSP will move many ACOs to greater downside risk. Attend our next boot camp on February 11–12 in Orlando to learn how your ACO can adapt to these changes and succeed with risk. The boot camp will feature presentations by technical experts, case studies from successful ACOs, and one-on-one assistance from faculty. Space is limited, so register today!
QPP WEBSITE UPDATED TO INCLUDE THIRD SNAPSHOT DATA FOR APM ENTITIES
CMS recently updated its Quality Payment Program (QPP) Participation Status Tool to include data from the third snapshot date for Alternative Payment Model (APM) entities used in determining Qualifying Payment (QP) thresholds. This third snapshot date will include data from Medicare Part B claims with dates of service between January 1 and August 31, 2018. For ACOs, a fourth snapshot date (December 31, 2018) will apply for determining which eligible clinicians (ECs) are participating in an ACO receiving MIPS APM status. To learn more about how CMS determines APM QP and Merit-based Incentive Payment System (MIPS) APM status for each snapshot date, please view the QP Methodology Fact Sheet. For more details on this process, access the CMS QPP Access User Guide. For more information on how the QPP applies to ACOs, please access our ACO Guide to MACRA.
CMS RELEASES DETAILS ON NEW CEHRT ATTESTATION REQUIRMENT EFFECTIVE IN 2019
In a recent ACO Spotlight newsletter article (January 2, Issue 2), CMS provided additional information on the new Certified EHR Technology (CEHRT) use attestation process that will be effective for all ACOs in 2019 and subsequent years. Effective for performance years 2019 and beyond, CMS has removed ACO Quality Measure 11: Use of CEHRT. Instead, ACOs will need to certify during an Annual Certification process that a certain percentage of the eligible clinicians (ECs) — as defined by MIPS — participating in the ACO use 2015 CEHRT. Specifically, for 2019:
- MSSP ACOs in Track 1 and Levels A, B, C, and D of the Basic Track are MIPS APMs and must certify that 50 percent of their ECs use 2015 edition of CEHRT.
- MSSP ACOs in Tracks 2 and 3, the Track 1+ Model, Level E of the Basic Track, and the Enhanced Track are Advanced APMs and must certify that 75 percent of their ECs use 2015 edition of CEHRT.
- ACOs that extended their agreement to June 30, 2019, will certify in the spring of 2019 via the ACO-MS. ACOs with a December 31, 2019, end date will certify in the fall of 2019 via the ACO-MS. Please note that ACOs participating in both six-month performance periods in 2019 will certify twice.
- More information about how and when to certify will be forthcoming as part of the annual certification process. CMS notes that if an ACO cannot certify it has met the threshold, CMS reserves the right to monitor, assess and/or audit an ACO’s compliance with respect to its certification of CEHRT usage among its clinicians.
SEEKING NAACOS MEMBERS FOR A NEW INITIATIVE TO IMPROVE CARE FOR HNHC PATIENTS
The Institute for Accountable Care is launching a demonstration project to improve care for high-need, high-cost (HNHC) individuals. The Institute is seeking ACO partners interested in developing and implementing: (1) Home visit programs to address unmet medical and social needs using community health workers, paramedics or nurses; and (2) Extensivist programs to manage care for patients with complex needs. The need to develop effective programs in these areas is growing as ACOs are pushed to take on more risk. Participating ACOs will receive technical assistance to help them launch programs efficiently and target patients effectively. The Institute will sponsor two learning collaboratives (for home visit and extensivist models) with experienced facilitators and expert faculty. We are seeking non-binding applications by January 25, 2019. Program details and application materials are available here. If you have questions, please contact Teresa Litton at [email protected].