CMS RELEASES 2022 PROPOSED MPFS RULE The Centers for Medicare & Medicaid Services (CMS) recently released the proposed 2022 Medicare Physician Fee Schedule (MPFS) Rule. The rule includes proposed updates to Medicare physician payment policies, updates to Quality Payment Program (QPP) requirements for 2022 as well as important changes to the Medicare Shared Savings Program (MSSP). Additionally, the rule includes proposed changes to quality measures and quality assessments for MSSP ACOs. Importantly, as a result of NAACOS advocacy, CMS proposes to allow ACOs to continue to report using the Web Interface in 2022 and 2023, phasing in the new electronic clinical quality measure (eCQM) reporting requirement over three years. NAACOS has strongly advocated for changes to the quality overhaul for a year and is pleased to see CMS propose some relief from burdensome aspects of the quality changes.
Some of the key issues affecting ACOs include these CMS proposals:
Decrease the Medicare conversion factor to $33.58, from $34.89, which was finalized for 2021, a drop of about 3.75 percent
Make changes to the quality reporting requirements for MSSP ACOs, including:
Allowing additional time to report using the Web Interface and phasing in the eCQM reporting requirement over three years (see Table 24 on p. 452)
Maintaining a 30th percentile quality performance standard for 2022 and 2023
Soliciting comments on whether CMS should further delay the eCQM requirement for ACOs and whether allowing TIN-level eCQM submission and altering the all-payer component of eCQMs for ACOs would resolve issues with this transition
Ease burdens and costs of ACO repayment mechanisms by cutting in half the percentages used in the existing repayment mechanism amount calculations
Seek comment on how CMS could consider revising ACO benchmarks to address concerns raised by NAACOS about including ACO beneficiaries in the regional expenditure calculation and using a blended national-regional growth rate for trending and updating benchmarks
Add new codes to the list of those used for ACO assignment, including newly created codes around chronic care management and principal care management
Reduce MSSP application burden by lowering document submission requirements around prior participation and sample and executed ACO participant agreements
Change beneficiary notification requirements for ACOs that select prospective assignment by only requiring notices to be sent to beneficiaries prospectively assigned to their ACO
Establish a new chronic care management (CCM) code, 99X21, which describes CCM services furnished by clinical staff under the supervision of a physician or non-physician practitioner (NPP) who can bill evaluation/management (E/M) services, and CCM services personally furnished by a physician or NPP
Remove telehealth’s geographic restrictions and add the beneficiary’s home as a permissible originating site for telehealth for the diagnosis, evaluation, or treatment of a mental health disorders; allow audio-only communication in the diagnosis, evaluation, or treatment of mental health disorders
Continue an “ongoing review of E/M visit code sets” and make several changes that take into account the previous changes to office and outpatient E/M visit codes that took effect January 1, 2021, as well as to clarify and refine certain provisions, including to allow split/shared E/M visits by a physician and NPP in the same group, and clarify that time a teaching physician is present can count toward E/M visit level for teaching services
The CMS MPFS factsheet and a QPP factsheet is available. NAACOS staff are currently reviewing the regulation and will provide a more thorough analysis to members shortly. Join us for our webinar reviewing these changes scheduled for July 29 from 2-3:15PM Eastern. Should you have any questions, please email us at advocacy@naacos.com.
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TODAY IS NAACOS’ NEXT DIRECT CONTRACTING LEARNING DISCUSSION Please join NAACOS and fellow Direct Contracting Entities (DCEs) today 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. The meeting will take place over Zoom and starts at 2:00 pm ET. Join us! Advanced registration is not required. If you have any problems logging on, please email DirectContracting@naacos.com. We plan to continue discussion around using claims data provided by Center for Medicare and Medicaid Innovation (CMMI) to pay downstream providers, among other topics. This is meant to be a safe space to discuss topics with peers.
IN-PERSON FALL CONFERENCE TOPICS ANNOUNCED 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. 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. We have special group rates for ACO members this year – visit the registration page to take advantage.
Topics featured will include:
Critical Policy Updates for ACOs
Direct Contracting Policy and Operations
Digital Healthcare
Quality Issues
Health Equity
Network Leakage and Keepage
Shared Savings and Physician Compensation
On-Demand Acute Care
Hospital at Home 2.0
Post COVID Lessons Learned, Opportunities and Challenges
Succeeding with Medicare Advantage
Leveraging ACO Infrastructure for the Entire Organization
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!
CONGRESS JUGGLES MULTIPLE PRIORITIES Congressional Democrats returned to Capitol Hill to address competing priorities of an infrastructure package and a reconciliation bill, which would include Majority priority items without bipartisan support. The concept is being touted as a “dual track” for these measures, while the White House has walked back the idea that the passage of either measure would be dependent on passage of the other. At the same time, House committees are working through appropriations markups. There is a very tight timeline to accomplish all these items, particularly given some unclear details regarding pay-fors for the infrastructure bill, but Congressional Democrats are pushing forward to deliver on multiple fronts prior to the August Recess. Also this week, the House released a report on high compensation for pharmaceutical manufacturers, and drug pricing continues to be a hot topic on the Hill and in the agencies.
NAACOS TO HOST CAPITOL HILL BRIEFING ON ACOS, VALUE-BASED CARE ACOs are invited to watch a virtual briefing NAACOS is hosting next week on the state of value-based care and changes in federal policy needed to advance it. Co-sponsors of the Value in Health Care Act have been invited to speak and will be joined by leading ACOs, who will offer their stories and examples of successes and challenges. The event, which is also an example of NAACOS’ work in Washington, is targeting congressional staff and other federal policymakers, but ACOs are welcomed to tune in. NAACOS members and business partners can register online, but if you have difficulty, please email dpittman@naacos.com to register.
COMING THIS FALL: SDOH LEARNING COLLABORATIVE NAACOS and the Institute for Accountable Care are planning a learning collaborative to help ACOs develop effective strategies to address social determinants of health (SDOH) affecting their patient populations. The collaborative will consist of a half-day in-person kick-off meeting followed by six virtual meetings that will focus on the following areas: needs assessment; resource identification; building a preferred network of community partners; evaluating closed-loop referral platforms; tracking outcomes; establishing payer partnerships; developing the business case for action; and advocacy for regulatory change and reimbursement. There is no cost to participate but interested ACOs will have to submit an application and space is limited. Additional details and a link to the application form will be provided in the July 29th newsletter.
NAACOS LETTER SEEKS POSITIVE CHANGES TO DIRECT CONTRACTING This week, NAACOS shared with CMMI Director Liz Fowler our latest round of recommendations on ways to improve the Direct Contracting Model. This is NAACOS’ third letter in seven months on the model, and we’re hopeful CMS will listen to our requests as the agency makes future updates. Among the letter’s many points, NAACOS asks CMS to:
Create “Enhanced Plus” to offer a full-risk option within MSSP;
Improve programmatic transparency by releasing more information about participants;
Increase shared savings rates for Professional DCEs;
Allow DCEs to switch capitation options;
Adjust performance year benchmarks to make it more equitable to legacy ACOs;
Institute risk adjustment changes to eliminate gaming and make risk adjustment more fair;
Reduce the discount for Global DCEs;
Improve data sharing with DCEs;
Issue fraud and abuse waivers; and
Stop the Geographic and Medicaid Managed Care Organization (MCO) options.
CMS RELEASES FIRST QP SNAPSHOT DATA CMS recently updated the QPP participation status tool to reflect the first Performance Year (PY) 2021 evaluation for meeting Advanced Alternative Payment Model (APM) thresholds, known as Qualifying APM Participant (QP) thresholds. Meeting or exceeding those thresholds is required to earn the annual Advanced APM bonus, which will be paid in 2023. The first “snapshot” period focused on January 1 through March 31, and providers have two more opportunities to meet the QP thresholds this year. Importantly, many more ACOs and providers will be eligible to earn Advanced APM bonuses as a result of NAACOS’s advocacy last year to prevent the QP thresholds from rising in 2021, as they were previously scheduled to before Congress changed them. To learn more about these bonuses, QP thresholds and how to qualify, please refer to NAACOS’s resource, The ACO Guide to MACRA.
CATCH THE ‘MODEL MATRIX’ WEBINAR SERIES ON-DEMAND In case you missed either or both parts of NAACOS’ June “Navigating the Model Matrix” webinar series, you can still catch it on demand. The 101 webinar provided a high-level review of key CMMI models and drew comparisons to previous, legacy models, including the Shared Savings Program. The 201 webinar, which had parts re-recorded to correct for technical difficulties, offered more in-depth discussion to help ACOs discuss key decision points evaluating participation in these models, strategies for dual program participation, where permitted, and optimizing model, track, and participant selection.
CMS NAMES NEW CENTER FOR MEDICARE DIRECTOR The Biden administration recently named Meena Seshamani as CMS deputy administrator and director of its Center for Medicare. This important office oversees the Shared Savings Program, along with other important Medicare operations. Seshamani understands the worlds of value-based care and ACOs as she was most recently vice president of clinical care transformation at MedStar Health, which is a NAACOS member. She also served on the Biden Transition Team and worked at HHS’s Health Reform Office during the Obama administration. Seshamani’s appointment is another example of CMS staffing up under the new administration. NAACOS is looking forward to meeting with her to discuss our priorities, which we outlined for new CMS Administrator Chiquita Brooks-LaSure in a letter last month.
NAACOS SUBMITS COMMENTS ON OMB RFI On July 6, 2021, NAACOS submitted comments in response to the administration’s request for information (RFI), “Methods and Leading Practices for Advancing Equity and Support for Underserved Communities through Government.” These comments highlight some of the ways ACOs are working to meet their patients’ social needs, leverage data to target underserved populations, and develop tools in order to improve health equity in the communities they serve. NAACOS then outlines recommendations for HHS and CMS, including creating new opportunities and funding for ACOs to address health equity, ensuring quality reporting is thoughtfully designed and implemented, testing telehealth expansions within the ACO model, and improving ACOs’ access to data needed for care coordination. NAACOS continues to develop policy priorities around health equity and facilitating ACOs’ ability to address these issues within their patient populations, as outlined in recent comments in response to the Health Equity RFI included in the 2022 Inpatient Prospective Payment Systems (IPPS) Proposed Rule.
NAACOS ENDORSES THE SOCIAL DETERMINANTS ACCELERATOR ACT Earlier this month, NAACOS endorsed the Social Determinants Accelerator Act of 2021 (H.R. 2503). This important piece of legislation will help states and communities devise strategies to improve the health and well-being of those participating in Medicaid by providing $25 million in planning grants and targeted technical assistance to develop and design innovative, evidence-based approaches to coordinate health and social services. The ultimate goals of this legislation are to facilitate cross-sector information exchange and coordination, improve health outcomes, and increase cost-effectiveness. NAACOS joined dozens of leading health and social services organizations on a letter supporting this legislation. NAACOS continues to support ACOs’ work to address social determinants of health, meet patients’ social needs, and improve health equity.
