LAWMAKERS LAYOUT COVID RELIEF PRIORITIES Over the next few weeks, lawmakers will be negotiating another COVID-19 relief package. Senate Republicans are planning to work with the White House to release a package next week highlighting their priorities. The package will then be negotiated with Congressional Democrats. Lawmakers are reportedly discussing a relief package that could include upwards of $1 trillion in relief funding for individuals, businesses, healthcare providers, and state and local governments. There are also ongoing discussions about drug price transparency, limits on surprise medical billing, and changes to telemedicine reimbursements. Congressional leaders anticipate votes before lawmakers depart for the August district work period. At the same time, Congress is also focused on advancing 2021 spending bills, including the HHS spending bill which passed the House Appropriations Committee and will likely be considered by the full House in the coming weeks.
SAHMSA ISSUES FINAL RULE ON SUD RECORDS HHS issued a final rule that aims to make it easier to share patients’ substance use disorder (SUD) treatment records. Following NAACOS advocacy, HHS included care coordination in the definition of “payment and health care operations,” which wasn’t in the proposed rule. Healthcare operations allow providers to share patient records after one-time consent, rather than seeking consent for each time the record is shared. HHS has issued a fact sheet and press release on the final changes. While NAACOS is pleased to see the changes, we’ve been advocating for full parity between the privacy of SUD treatment records and Health Insurance Portability and Accountability Act (HIPAA). Congress passed a law that created that parity this spring, and HHS said in the final rule that additional rulemaking will be needed to enact those changes.
REGISTRATION NOW OPEN FOR FALL 2020 VIRTUAL CONFERENCE Mark your calendars for September 22 through October 2 for the NAACOS Fall 2020 Conference. We plan to build on the successes of our recent virtual June Conference and apply several lessons learned. This unique opportunity will take place Tuesdays through Fridays of those weeks, with more sessions as well as opportunities to interact with peers and vendors. Content will feature topics around operational tactics, clinical best practices, and updates on policy and regulation from ACO experts and CMS officials. The program will also feature strategies for adapting to the COVID pandemic. As in the past, all the content will be available to access for the following six months.
Register before August 7 at a discount of $100 per person! Registration is open to all individuals, regardless of membership status.
New This Conference: Virtual Exhibit Hall The Fall 2020 Conference will feature a virtual exhibit hall where attendees will be able to meet with exhibitors online! The virtual exhibit hall is complementary to all business partners in good standing. Features will include virtual meet-ups, virtual networking, product photos, and MUCH more! Sponsorship packages are available and designed to maximize this virtual format.
Packages available include:
$25K Level with 30-minute live session on Tuesday or Wednesday of the virtual conference
$10K Level with 12-minute recorded commercial played between sessions during the virtual conference
DID YOU MISS IT? NEW WEBINAR: HOW TO ACCESS EMERGENCY FUNDS On July 15th KPN hosted a webinar entitled ACO Operational Continuity: Revenue Recovery, Operational Excellence in Today’s Economic Environment. Financial strategies and the crucial timing to access emergency funds were discussed by a panel of experts. For your convenience, NAACOS has recorded the session so you can collaborate with your staff, or simply watch at your leisure. View the webinar today!
IAC’S NEW SERVICE CALCULATES QP SCORES BY PHYSICIAN GROUP The Institute for Accountable Care (IAC) is now using its Medicare claims database to help MSSP ACOs understand the marginal contribution of each of its physician groups (TINs) to its overall Qualifying APM Participant (QP) score. In order for eligible clinicians to earn the 5 percent Advanced Alternative Payment Model (APM) bonus ACOs must receive at least 50 percent of Medicare Part B payments or see at least 35 percent of Medicare patients through an Advanced APM entity during one of three determination (i.e., snapshot) periods. IAC can use its data to model the impact of different TIN configurations on an ACO’s 2021 QP scores. This service is provided for a fee. If you would like to learn more, please contact the Institute by email at analytics@institute4ac.org.
NAACOS WRITES TASKFORCE ON TELEHEALTH POLICY In a letter to an influential, multi-stakeholder taskforce, NAACOS urged the group to recommend offering more telehealth payment waivers for all ACOs because of their hypersensitivity to fraud and overuse. The newly formed Taskforce on Telehealth Policy, which is being convened by the American Telemedicine Association, National Committee for Quality Assurance, and Alliance for Connected Care, is set to make its recommendations in September on how policymakers can expand the use of telehealth. NAACOS is very supportive of telehealth and wants to see gains in its utilization continue after the public health emergency ends. ACOs are a great vehicle for more flexible policies because of their foothold on value-based care while preventing over utilization of telehealth, which is a cause of concern.
PY 2021 CHANGE REQUEST DEADLINE IS NEXT WEEK As a reminder, ACOs have until noon ET on July 20 to make a series of initial change requests for Performance Year (PY) 2021. These include “freezing” your participation on the Basic Track’s glidepath, electing an additional performance year if your contract is set to expire at the end of 2020, adding or deleting ACO participants, applying for a Skilled Nursing Facility Three-Day Stay Waiver, choosing assignment methodology, and selecting a minimum savings rate (MSR)/minimum loss rate (MLR) if moving to a risk-based track. More information can be found on CMS’s website on MSSP application.
PAYMENT RULES RELEASED WHILE MPFS RULE REMAINS UNDER REVIEW CMS recently released the Home Health Prospective Payment System and Medicare End-Stage Renal Disease (ESRD) Prospective Payment System proposed rules for 2021. CMS estimates that Medicare payments to home health will increase in aggregate by 2.6 percent. CMS projects updates will increase total payments to ESRD facilities by 1.6 percent. The Medicare Physician Fee Schedule (MPFS) rule remains under review at the Office of Management and Budget (OMB) and is expected to be released any day.
BIDEN TASK FORCE RECOMMENDATIONS AND ACOS The campaign of former Vice President and presumptive Democratic presidential nominee Joe Biden recently released a lengthy policy platform, and it mentions the need for ACOs and alternative payment models as a cost-containment strategy. While not devoting lengthy discussion to the topic, the platform includes “increase, encourage and support for alternative payment models” and “expand and improve opportunities” for ACOs as part of its “coverage and cost” recommendations.
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CMS RELEASES REPORT ON 2018 QPP CMS recently released a report with details about 2018 participation in QPP, which corresponds to Medicare Part B payment adjustments made in 2020, including those for the MIPS and Advanced Alternative Payment Models (Advanced APMs). Findings from the report reveal that there were almost 900,000 eligible clinicians (ECs) in MIPS. Approximately 360,000 of those were in a MIPS APM, with 98 percent of those earning that designation from their MSSP participation. The vast majority of MIPS ECs earned positive payment adjustments with a high payment adjustment of 1.68 percent. The CMS report also includes additional details, such as performance on various MIPS measures and reporting options used by ECs.
In 2018, if an EC participated in an Advanced APM and a certain proportion of payments were considered through the Advanced APM, the EC became a Qualifying APM Participant (QP), earning a 5 percent bonus that will be paid in 2020. NAACOS has repeatedly advocated that Advanced APM bonuses be paid in the first half of the payment year, and we will continue to urge CMS to release those payments as soon as possible, especially in light of the drop in revenue from lower utilization stemming from the COVID-19 pandemic. Table 7 of the report shows the average QP scores across APMs. In the report, CMS specifies there were 183,000 clinicians that earned Advanced APM bonuses. While that number increased from PY 2017 to 2018, there is still a considerable imbalance between how many clinicians are in MIPS compared to QPs. NAACOS recommends policymakers improve existing Advanced APMs to attract new providers and to retain existing participants long-term to support a meaningful shift to value-based care. We also continue to advocate to revise QP thresholds and extend the Advanced APM bonus. For more information on ACO participation in QPP, please refer to NAACOS’s resource, The ACO Guide to MACRA.
NAACOS SUBMITS COMMENTS IN RESPONSE TO RFI REQUEST NAACOS recently submitted comments to HHS in response to a request for information (RFI) on how to ensure health system resilience post COVID-19. NAACOS comments stress the need to strengthen the ACO model and other total cost of care models to increase health system resilience as we recover from COVID-19. Other issues highlighted include requests to:
Extend the public health emergency through December
Make certain telehealth waivers permanent
Make 2020 ACO quality measures pay-for-reporting
Address APM overlap
Provide ACOs access to valuable and actionable real-time data needed for care coordination
HHS ANNOUNCES $4 BILLION IN RELIEF FOR SAFETY NET AND RURAL HOSPITALS Last week, HHS announced an additional $4 billion in relief payments to providers affected by the coronavirus pandemic. These funds are specifically for safety net hospitals, rural providers, and other providers from small metropolitan areas. Previous funding for safety net hospitals did not reach certain acute care hospitals that were unable to qualify, and HHS has subsequently revised the qualifying criteria to include certain acute care hospitals. HHS is also expanding a payment formula to cover certain special rural Medicare designation hospitals in urban areas as well as others who provide care in smaller non-rural communities.
CMS PUBLISHES PROVIDER ENGAGEMENT TOOLKIT ACOs looking for help in engaging participating providers have a new resource in a toolkit just published from CMS. The provider engagement toolkit specifically addresses how to communicate with clinicians about an ACO’s work, using data to improve care, supporting primary care providers and specialists, and creating financial incentives for ACO providers. CMS has previously published toolkits on beneficiary engagement and care coordination, which can be found on the agency’s ACO General Information page.
HHS REPORT ON SOCIAL DETERMINANTS AND VALUE-BASED PAYMENT The Office of the Assistant Secretary for Planning and Evaluation (ASPE) recently released a second report to Congress examining the effect of individuals’ social risk factors on quality measures, resource use and other measures of Medicare’s value-based payment programs. The report also discusses how HHS can achieve better outcomes for beneficiaries by facilitating the ability of providers and communities to address social risk factors and integrate health and social services. This report was required by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. The executive summary of the report, entitled Social Risk and Medicare’s Value-Based Purchasing Programs is available on the ASPE website. The report identifies three main strategies, measuring and reporting quality using social risk information, setting high and fair quality standards using social risk information, and rewarding and supporting better outcomes to better address beneficiaries’ social needs directly.
