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NAACOS TO HOLD FALL CONFERENCE IN WASHINGTON, DC Join us in Washington, D.C., September 29–October 1, to hear from leading ACO experts and CMS officials sharing timely and essential information for ACOs. While we are eager to see you in-person, the conference sessions will also be available live through our streaming service and recorded for post-conference viewing. We will be releasing specific agenda information during the next few weeks.
Register Early and Save Register before August 27 for the in-person conference and receive a discount of $300 per person. Can’t attend in person? Register for our live webcast before August 27 and receive a discount of $100 per person.
New This Year Take advantage of our group rates! We are offering group rates for both the in-person and virtual conference. To register at the group rate, please contact Emily Perron. Group rates are only available to NAACOS member ACOs. If your ACO is not a member, join now and save!
Hotel Reservations Marriott Marquis Washington, DC 901 Massachusetts Avenue, N.W. Washington, DC 20001
All reservations must be made by August 27 to qualify for the discounted room rate of $289 plus taxes (based upon availability). Marriott has gone to great lengths to ensure a safe environment at the Marriott Marquis. Read more about their “commitment to clean.”
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. Reserve your space today!
2021 QPP ADVANCED APM BONUSES RELEASED The Centers for Medicare & Medicaid Services (CMS) recently began issuing annual 5 percent bonus payments to those who qualify for Advanced Alternative Payment Model (APM) incentives through the Quality Payment Program (QPP). These payments are related to 2019 performance, and eligible clinicians had to qualify based on Advanced APM participation and meeting Qualifying APM Participant (QP) thresholds. In past years, these bonuses were issued later in the year. The expedited payment timeline has been an advocacy item for NAACOS, as communicated in this letter, and we are pleased to see the payments distributed much earlier.
CMS also recently published a notice, accessible through a document, with names of qualifying clinicians whose billing information the agency cannot verify to issue payments. Clinicians on that list need to contact CMS by November 1 to provide updated information so CMS can issue their Advanced APM bonuses. More information on the Advanced APM bonuses can be found in this CMS factsheet and guide. For additional information on Advanced APMs and the QPP, please visit NAACOS’ dedicated MACRA page with a number of resources and advocacy items.
CONGRESS MOVES FORWARD WITH INFRASTRUCTURE DEAL Last week President Biden announced that the White House and a group of bipartisan lawmakers have arrived at a deal on infrastructure legislation. While all of the details of the deal are not yet final, it is believed that the legislation will primarily focus on brick-and-mortar projects, as well as targeted tax provisions. While the concept of a two-track package—including both infrastructure and other “reconciliation” Majority priorities — was raised initially by President Biden, that idea received tremendous push back both from progressive Democrats and Republicans who had endorsed the bipartisan plan. Both measures are currently being worked on in both chambers, with the prospects for a reconciliation bill that advances progressive priority items presently unclear. NAACOS is monitoring these legislative developments, as well as continued interest in work on a “public option,” modifications to the Affordable Care Act, and work around a CURES 2.0 bill, to identify areas of interest for ACOs and vehicles to advance our legislative priorities.
TELL CONGRESS TO SUPPORT ACO “RURAL GLITCH” BILLS NAACOS is asking members and business partners to take a few minutes to write their members of Congress to ask that they sponsor the Accountable Care in Rural America Act (H.R. 3746). This legislation corrects what we call the “rural glitch,” although it would help many urban and suburban ACOs, too. The rural glitch disadvantages ACOs by including ACO-assigned beneficiaries in the regional adjustment of the benchmark. When ACOs lower the cost of care of their assigned populations, they also remove the advantage the regional adjustment gives. To help, NAACOS has drafted a letter, which should be personalized, to ask for lawmakers’ support. Don’t forget to include your organization’s name at the end. NAACOS is advocating hard on this issue, but we could use your help. Visit our take action page now!
VIEW OUR RECORDING, CONQUERING ECQM REPORTING CMS recently finalized a number of changes to the way ACOs report and are evaluated on quality for purposes of both the Medicare Shared Savings Program (MSSP) and Merit-Based Incentive Payment System (MIPS), including a requirement that ACOs move to electronic reporting of quality data through electronic Clinical Quality Measures (eCQMs). As your ACO prepares to implement these changes, learn from your peers by viewing a complimentary recording of the session, Conquering eCQM Reporting, held at our recent Boot Camp. In this session, NAACOS staff review the new quality requirements for ACOs and two leading ACOs share best practices and implementation strategies for moving to eCQM reporting. You can also learn more about the new requirements by accessing our member resource. NAACOS has also developed a grassroots action alert asking CMS to make needed changes to this new quality structure for ACOs. Take action today by sending a letter to the agency asking CMS to delay the mandatory reporting of eCQMs to give ACOs and the electronic health record (EHR) industries more time to prepare for this significant shift.
INNOVATION CENTER’S HOME HEALTH MODEL PROPOSED TO EXPAND NATIONWIDE In a recently proposed 2022 payment rule for home health agencies (HHAs), CMS is proposing to expand nationally the Center for Medicare and Medicare Innovation’s (Innovation Center’s) Home Health Value-Based Purchasing Model, which has proven to both improve quality and lower costs for home health. Under the model, payments to HHA are adjusted upward or downward by as much as 7 percent in 2021 based on quality and efficiency measures. It has been piloted in 9 states since 2016 but would expand to the entire country under the proposal from CMS. Given the role post-acute and home health care can play in ACOs’ care management strategies, the expansion of this model is notable. Elsewhere in the proposed rule, CMS estimates payments to home health agencies would increase by 1.7 percent or $310 million based on the proposed policies.
UPDATED COMPARISON CHART FOR HIGH-RISK ACO MODELS NAACOS has updated the member resource that compares in a side-by-side chart several high-risk ACO options, including Track 3, MSSP Enhanced, the Next Generation ACO Model, and Direct Contracting options. Fields in the chart include high-level characteristics, financial details, differences in assignment, quality reporting, compliance, and waivers. The chart is meant to serve as a guide for ACOs looking to navigate the field of high-risk ACO options and better understand model characteristics, particularly for those ACOs still weighing participation options for 2022.
NAACOS BCAPA TOOL AVAILABLE TO MEMBERS NAACOS is in the process of making changes to the Benchmarking Comparison and Performance Analysis (BCAPA) Portal and updating the data through 2020 (or possibly Q1 2021). We anticipate these updates will be finished by the end of the summer, and we will notify members when the updated portal is ready. As always, NAACOS MSSP ACO members’ own ACO-level reports are complimentary. 2017–2019 data is currently available.
NAACOS’ NEXT DIRECT CONTRACTING LEARNING DISCUSSION ON JULY 15 Please join NAACOS and fellow Direct Contracting Entities on July 15 for our next Direct Contracting Learning Discussion. The event is meant for DCEs that are participating in or planning to participate in the Global and Professional Direct Contracting Model to share feedback, questions, concerns, and points of interest. This collaborative discussion will provide a forum for shared learning. If you have questions or topics of conversation you want discussed, please share them in advance by emailing directcontracting@naacos.com. We plan to continue discussion around using claims data provided by the Innovation Center to pay downstream providers, among other topics. This is meant to be a safe space to discuss topics with peers.
NAACOS CO-HOSTS CAPITOL HILL BRIEFING ON HEALTH EQUITY On June 29, NAACOS co-hosted a briefing entitled “Alternative Payment Models: A Springboard for Achieving an Equitable Healthcare System.” Speakers from Atrium Health, Advocate Aurora, Henry Ford Health System, Families USA, and Baycare Health Partners explained how health equity initiatives have been advanced via value-based care models, as well as recommendations for future clinical and policy activities. Presentation and speaker biographies are available. The event was also supported by other leading healthcare associations and organizations including Premier, America’s Essential Hospitals, America’s Physician Groups, the Healthcare Leadership Council, and more. This event is one in a series of initiatives that NAACOS is undertaking to advance understanding of value-based care programs on Capitol Hill and with key policymakers.
PROFESSIONAL DCES MAY TRANSITION TO FULL-RISK GLOBAL DCE The Innovation Center recently announced in a Direct Contracting newsletter that it will allow Professional DCEs participating in Performance Year (PY) 2021 to switch and become Global DCEs effective for PY 2022, a policy change that has been part of NAACOS’ advocacy. Any DCE making this election must do so by September 10, 2021. The Innovation Center also reconfirmed that Global DCEs may not switch to the lower-risk Professional DCE option but clarified during an office hours call that Global DCEs will be able to switch their capitation elections between primary care capitation and total care capitation on an annual basis.
NAACOS SUBMITS COMMENTS ON HOSPITAL PAYMENT RULE On June 28, 2021, NAACOS submitted comments in response to CMS’s proposed Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2022 Rule (IPPS Rule). NAACOS provided comments on three sections of the proposed rule, including policy changes to the MSSP, a health equity request for information (RFI), and an RFI on the use of Fast Healthcare Interoperability Resources (FHIR). Regarding MSSP, NAACOS recommends that CMS finalize with modification the proposal to allow ACOs to elect to remain in their current level of the Basic glide path for PY 2022, but that CMS should not automatically advance ACOs to the level in which they would have been without this policy in order to ensure ACOs can successfully transition to levels with downside risk.
In response to the health equity RFI, NAACOS describes work ACOs are doing to target and reduce inequities, noting that ACOs need appropriate tools, data, financial incentives, and resources to address health equity. Recommendations include providing flexibility in Medicare rules to allow ACOs to deliver supplemental benefits and upfront funding for health equity initiatives. Additionally, NAACOS recommends modifications to new quality reporting requirements, testing telehealth expansions within ACOs, and providing ACOs with substance use disorder (SUD) data needed for care coordination. Lastly, in response to the FHIR RFI, NAACOS highlights key challenges ACOs face in the move to eCQMs and digital quality measurement. ACOs must bring together data across many EHRs, and practices may work across different EHRs and have very different workflows, making aggregation challenging and costly, so it is critical that CMS recognize the nuances and challenges that exist for ACOs. NAACOS will be providing additional feedback on this issue in response to the proposed 2022 Medicare Physician Fee Schedule, which is expected to be released soon.
ACO IMPLICATIONS FROM SUPREME COURT’S ACA DECISION Two weeks ago, the U.S. Supreme Court dismissed a challenge to the Affordable Care Act (ACA), California et. al. v. Texas et. al., ruling that the plaintiffs challenging the legality of the law had not sufficiently established standing to bring the suit. Justice Breyer delivered the majority decision of the court; only Justices Alito and Gorsuch dissented. The MSSP and the establishment of the Innovation Center were both codified in the ACA, therefore, the Court’s affirmation of the ACA ensures that the MSSP and Innovation Center are here to stay.
This Supreme Court challenge was the third significant challenge to the ACA, and the Court’s decision has been heralded as the ‘final’ decision on the matter. Statements by Republican policymakers following the decision suggest that another ACA lawsuit challenging the law’s constitutionality is not part of the immediate strategy for the law’s opponents. At the same time, many proponents of the ACA acknowledge that modifications to the law may be necessary to ensure that its goals of health care access and coverage are realized. If legal options for such modifications have been precluded, we may see additional legislative proposals gain traction to augment and improve the ACA. NAACOS will continue to monitor these issues, and the decision is available to read now.
JUNE 2021 MEDPAC SUMMARY AVAILABLE Earlier this month, the Medicare Payment Advisory Commission (MedPAC) released its annual June report to Congress. NAACOS has summarized key elements of the report most relevant to ACOs. The report makes recommendations on APMs, suggesting that CMS implement a more harmonized portfolio of fewer APMs that are designed to work together to support common strategic objectives. This is in line with what we have been hearing from the administration about the direction of APMs, including from Innovation Center Director Liz Fowler at the NAACOS Spring 2021 Conference earlier this year. Some specific recommendations include focusing on a single population-based model with different tracks and testing innovations or other types of models within the framework of the population-based model or encouraging states to pursue waivers to operate state-specific models such as the Vermont multi-payer ACO model. NAACOS is pleased to see MedPAC highlight the success of ACOs and dedicate attention to the move to value.
