Newsletter for Members and Partners June 06, 2019
NAACOS Provides input on the Direct Contracting Model
NAACOS Urges CMS to make Next Gen permanent
NAACOS Solicits Board Nominations
NAACOS Resources on New Payment Models
NAACOS Files Comments on Two Important Health IT Rules
NAACOS Upcoming Webinars
June NOIA Deadlines Approach for ACOs Staring January 1, 2020
CMS Delivers MSSP Q1 Report Package
CAHPS for ACOs Benchmark Changes
Innovation Center Clarifies Next Gen SNF Waivers
NAACOOL Is Way Cool
White House Preparing Executive Order on Health Care Prices
Bipartisan Senate Bill Addresses Health Costs
CMS Releases FAQs for Innovation Center’s ET3
House Moving Forward on Appropriations
New appointments to MedPAC announced
NAACOS PROVIDES INPUT ON THE DIRECT CONTRACTING MODEL
In response to a request for information from the CMS Innovation Center, NAACOS recently submitted comments on the Direct Contracting Model. In the comments, NAACOS urged the Innovation Center to launch the Geographic Population-Based Payment (PBP) Option, one of three options under the new model, in areas where there is low ACO penetration. NAACOS also asked the Innovation Center to exclude ACO-assigned beneficiaries from the populations for which Geographic Direct Contracting Entities (DCEs) would be responsible.
Since many ACOs are more likely to participate in the Professional and Global PBP options, NAACOS also sent a separate letter to Innovation Center Director Adam Boehler, providing feedback on how to optimize those models. NAACOS is pleased the Direct Contracting Model builds off many ACO principles. NAACOS also issued a press release on the two letters and joined a sign-on letter asking Geographic DCEs not to take precedence over ACOs or generally harm competition in Medicare.
NAACOS URGES CMS TO MAKE NEXT GEN PERMANENT
NAACOS reiterated its call to HHS Secretary Alex Azar to make the Next Generation (Next Gen) ACO Model a permanent, voluntary offering in the MSSP. In a letter from 10 associations representing providers, NAACOS and others called for the Next Gen model to be a permanent option beginning with the 2021 performance year. The letter notes the program has demonstrated the savings and quality improvement necessary to be certified as a permanent Medicare program. Last month, NAACOS sent a similar letter to Azar and CMS Administrator Seema Verma that also asked for additional changes to the model to improve the program.
NAACOS is soliciting nominations for our 2020 Board Member Election, which will open August 1. The NAACOS Board of Directors’ purpose is to advance the core mission of NAACOS to foster growth of the ACO model of care. Board members represent a diverse range of ACO interests and help shape NAACOS priorities, such as educating ACOs in operational and clinical best practices, advocating on behalf of ACOs with Congress and the Executive Branch, and educating the public about the value of accountable care. To be a NAACOS board member, candidates must be employed as executives of ACO members in good standing at all times during their term of office. For the upcoming election, there are three ACO single-entity board seats available. Although members may submit nominees for any category, member types vote for their own representatives, so only single entity ACO members will be voting this year. To nominate a candidate for the board, please complete this form. Nominations will be accepted through June 28. If you have any questions, please email Anna LaFayette or call (202) 640-2492.
Board Member Expectations
- Serve a three-year term, January 1, 2020 – December 31, 2022
- Attend four 90-minute board meetings a year via webinar
- Attend two in-person conferences per year and any meetings that are scheduled within that conference, including but not limited to: membership meetings, VIP receptions, and board breakfast meetings
- Attend an in-person board retreat every other year (next retreat Fall 2020)
- Participate in the conferences by planning, organizing, moderating or speaking as requested
- Serve as discussants on webinars hosted by NAACOS as needed
- Participate in surveys, membership campaigns, and elections when requested
Part of NAACOS’ mission is to provide educational materials for ACOs to better understand government regulations, new programs, and model changes. NAACOS works to create custom educational materials, including resources and webinars, specifically for ACOs. Below are recently developed resources:
- Chart comparing Direct Contracting and other high-risk ACO models
- CMMI Session from the spring conference, available on-demand
- Chart of CMS Innovation Center models and their overlap with ACOs
- Summary of the Primary Care First Model
NAACOS FILES COMMENTS ON TWO IMPORTANT HEALTH IT RULES
NAACOS recently submitted two letters in response to the release of health IT rules. Recognizing the importance of interoperability to ACOs’ work, NAACOS was supportive of efforts by CMS and HHS’s health IT office to spur the exchange of patient data across the health system. The proposed HHS rule implements the 21st Century Cures Act of 2016, which makes it illegal to intentionally block the flow of patient medical records. Among other things, in the letter NAACOS supports the concept of a new application programming interface certification criterion to support population-level data access, asks for a narrower definition of electronic health information to include relevant clinical data, and urges that ACOs be excluded from definitions of health information networks and exchanges.
CMS also proposed to require hospitals share electronic notifications of patients’ admission, discharge, and transfer (ADT) with other facilities and community providers. In the letter to the agency, NAACOS was supportive of CMS’s efforts in this area while also recommending modifications to enhance the feasibility of such a requirement. In addition to this letter, NAACOS also joined 32 others in a separate letter to CMS asking the agency to finalize the ADT-sharing requirement. Lastly, NAACOS asked members to write their own comment letters to CMS through our website, and we thank those of you who did. Your support makes it more likely CMS will finalize the sharing of ADT feeds.
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| The Polyclinic Seattle, WA |
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NAACOS UPCOMING WEBINARS
NAACOS has two, FREE to all, partner-sponsored webinars coming up in June.
| Value-based Reimbursement Strategy and Performance by Cerner Do you need to maximize and measure program performance of new care initiatives aligned with value-based reimbursement models? During this webinar, Angie Massey and Larry Howe, senior population health strategy executives with Cerner will discuss how to optimize your value-based payment strategies and analytics. With a disciplined approach, you can measure and drive performance by overcoming silos, identifying relevant processes, gathering stakeholder input, and capturing baseline data to help develop goals and a program road map. June 11 3:00 – 4:00 p.m. ET for all participants – Register Now! |
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| Securing the A in MA: Strategies for Success in Medicare Advantage Value-based Contracting by Milliman Value-based payment arrangements with Medicare Advantage (MA) plans have proliferated in the past one-to-two years. Providers can certainly gain significant advantages from such arrangements. However, MA can also be a complex, technical minefield. In this webinar, attendees will learn key strategies for success in MA value-based payment and best practices for avoiding the most common pitfalls from speakers Simon Moody, principal and consulting actuary, Milliman; Matt Kramer, consulting actuary, Milliman; and Kelly Henry, senior director, UCHealth. June 21 11:00 a.m. – 12:00 p.m. ET for all participants – Register Now! |
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JUNE NOIA DEADLINES APPROACH FOR ACOS STARTING JANUARY 1, 2010
For ACOs interested in applying to participate under the new Pathways to Success program structure with a January 1, 2020 start date, please note the Notice of Intent to Apply (NOIA) period will open on June 11 and will close on June 28 at 12:00 p.m. ET. Applications will be accepted July 1 to July 29 at 12:00 p.m. ET. As a reminder, submitting an NOIA is non-binding. More information including updated NOIA guidance is available on the CMS website. More information about the new program structure created by the Pathways to Success Rule is available in our member analysis. Finally, ACOs wishing to terminate their participation for the six-month performance period of January 1 to June 30, 2019, must provide at least 30 days’ advance written notice to CMS and its ACO participants of its decision to terminate, along with the effective date of termination. CMS notes that ACOs that select a termination date before June 30 are not financially reconciled, while ACOs that terminate on or after June 30 are financially reconciled for the six-month performance period and will be required to report quality for the entire calendar year 2019.
CMS DELIVERS MSSP QUARTER 1 REPORT PACKAGE
CMS recently provided Medicare Shared Savings Program (MSSP) ACOs with their 2019 Quarter 1 (Q1) Report Packages via the Managed File Transfer (MFT) mailbox and the SSP ACO Portal. The report package includes a cover notice and the following: Assignment List Report, Assignment Summary Report, Aggregate Expenditure/Utilization Report, Non-Claims Based Payment File, and 2018 Q4 Claims-Based Quality Measures Report. This file will be available in ACOs’ MFT mailboxes for 30 days from the delivery date and through the SSP ACO Portal indefinitely.
Of note in the Q1 Report Package, CMS includes a new Regional Expenditures Report Table, which provides non-risk adjusted regional expenditures for an ACO’s third benchmark year and for each quarter by the four Medicare enrollment types. The regional expenditures for each enrollment type presented in Table 2 are a weighted average of county fee-for-service (FFS) expenditures with weights reflecting the proportion of the ACO’s assigned beneficiary person years residing in each county for that enrollment type in that year. This new information should help ACOs keep track of how they are doing under the regional benchmarking methodology.
CAHPS FOR ACOS BENCHMARK CHANGES
CMS recently noted in the ACO Spotlight Newsletter that scores for Performance Year (PY) 2017 are not comparable to PY 2018, due to the utilization of a more streamlined version of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for ACOs survey. CMS notes benchmarks for PY 2018 have also been updated to address these changes. ACOs will receive their quality performance reports and CAHPS for ACOs reports for PY 2018 later this summer, according to CMS.
INNOVATION CENTER CLARIFIES NEXT GEN SNF WAIVERS
In an updated frequently asked questions (FAQs) about the Skilled Nursing Facility (SNF) Three-Day Rule Waiver for Next Gen ACOs, the Innovation Center clarifies that the Next Gen Model takes priority when providers are responsible for beneficiaries in both the Bundled Payments for Care Improvement (BPCI) Advanced Model and Next Gen ACOs. Therefore, if Next Gen beneficiaries are admitted to SNFs using the Three-Day Rule Waiver, the stay will be considered a Next Gen waiver stay. Furthermore, SNF admissions are no longer excluded from quarterly data submissions or analysis based on BPCI participation. NAACOS in the past has advocated that total-cost-of-care models like ACOs should take precedence over other payment models, and we are pleased to see CMS make this clarification.
NAACOOL IS WAY COOL!
Has your ACO or Business Partner authored a white paper, article, or report that advances the ACO model? Do you wish to share it on a national platform? Then submit to NAACOS’ online library. NAACOOL which stands for National Association of ACOs Online Library is an educational tool exclusive for NAACOS ACOs and Business Partners to utilize. Articles, white papers, publications, reports, presentations, and more comprise NAACOOL. With an easy-to-use keyword search, NAACOOL is a fantastic resource and is essential for any entity (ACO or Business Partner) wishing to navigate the ACO environment. NAACOOL embodies the spirit of best-practice-sharing among ACOs and those who serve them. To submit to NAACOOL, please email our staff at [email protected] for review. Use NAACOOL submission in the subject line.
WHITE HOUSE PREPARING EXECUTIVE ORDER ON HEALTH CARE PRICES
The President is preparing to sign an executive order that would require greater price disclosure in the health care industry. While the Trump administration has taken several steps to increase health care transparency in drug and hospital prices, it’s anticipated that this executive order will be the most sweeping executive action taken on health prices. It’s expected to mandate the disclosure of pricing data on the negotiated rates between insurers, hospitals, and physicians. The final executive order is expected to be released in the near future, and NAACOS will be closely following the administration’s actions to evaluate its impact on ACOs.
BIPARTISAN SENATE BILL ADDRESSES HEALTH COSTS
On May 23, Sens. Lamar Alexander (R-TN) and Patty Murray (D-WA), the Chairman and Ranking Member of the Senate Health, Education, Labor, and Pensions (HELP) Committee introduced the Lower Health Care Costs Act of 2019. The bipartisan HELP legislation is the most comprehensive drug pricing, surprise billing, and transparency legislation introduced to date. It will serve as the foundation for a Senate health care package that will also include drug pricing and transparency provisions from the Senate Committees on Finance and Judiciary. Committee leaders have made it clear they want to have legislation ready for floor consideration in July. The HELP legislation would prohibit surprise billing for emergency care services in one of three ways. First, it would create an in-network guarantee at hospitals. Second, surprise medical bills would be paid at the median contracted rate in a geographic area. Third, it allows the Department of Health and Human Services (HHS) to establish an independent dispute resolution process for bills larger than $750. The legislation also includes several provisions on health IT and transparency that would:
- Ban gag clauses and anticompetitive terms in facility and insurance contracts;
- Establish a national health care payment database;
- Require a Government Accountability Office (GAO) study on profit-sharing relationships between hospitals, contract management groups, and physician and ancillary services; and
- Incentivize health care entities’ to adopt strong cybersecurity practices by encouraging the Secretary of HHS to consider entities’ adoption of recognized cybersecurity practices when conducting audits or administering fines related to HIPPA rules.
The CMS Innovation Center recently posted more information on its recently announced Emergency Triage, Treat, and Transport Model (ET3), which will pay ambulance providers to take patients to sites of care besides outpatient emergency departments or to treat patients on-site. The information includes both FAQ sheet and a request for applications. The online portal to apply for the model will open later this summer. In the FAQ, CMS says it “will address participant-specific issues pertaining to overlapping participation in other CMS initiatives in CMS’s sole discretion, as necessary.”
HOUSE MOVING FORWARD ON APPROPRIATIONS
Although Congressional leaders and the White House have not yet come to terms on a long-term budget agreement for FY 2020, the House is still moving forward with the annual appropriations process. The House Appropriations Committee continues to approve FY 2020 spending bills, and the House Majority Leader’s office recently announced that the House will begin considering appropriations bills on June 12. Leaders want to pass as many spending bills as possible before the July 4th Congressional recess. Democratic leaders are planning to bundle five FY 2020 spending bills (Labor-HHS-Education; Defense; Energy-Water; State-Foreign Operations; and Legislative Branch) into one large package for consideration on June 12. The Labor-HHS-Education bill includes $189.9 billion in base discretionary funding, an increase of $11.8 billion over the 2019 enacted level and $48 billion over the President’s 2020 budget request. The Senate Appropriations Committee has not yet released fiscal 2020 spending bills because the House, Senate, and White House have not yet finalized a budget agreement.
NEW APPOINTMENTS TO MEDPAC ANNOUNCED
The Medicare Payment Advisory Commission, which makes recommendations on Medicare pay policies, will see two new members when its next work session starts in September. Lawrence Casalino, physician and professor at Weill Cornell Medical College, and Amol Navathe, health policy professor at the University of Pennsylvania School of Medicine, will serve on MedPAC through April 2022. Brian DeBusk, CEO of DeRoyal Industries; Paul Ginsburg, health economist and professor with Brookings and University of Southern California; Bruce Pyenson, actuary with Milliman; and Pat Wang, CEO of Healthfirst, were all reappointed for three-year terms.