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NAACOS-BACKED ACO RURAL GLITCH BILL RE-INTRODUCED On June 9, a bipartisan group of U.S. Representatives — Reps. Arrington, DelBene, Kelly, Bera, O’Halleran, Sewell, Dunn, and Gooden — introduced H.R. 3746, the Accountable Care In Rural America Act, which would fix Medicare Shared Savings Program (MSSP) benchmarks by correcting the “rural glitch” policy that unfairly penalizes ACOs when they reduce costs relative to their region. Specifically, the bill would remove an ACO’s expenditure data from the regional component of the ACO’s benchmark. NAACOS has repeatedly advocated to fix this benchmarking flaw, urging action from the Center for Medicare & Medicaid Services (CMS) as well as calling on Congress to intervene. It’s essential to have fair and accurate benchmarks for the program — and individual ACOs — to succeed. Further, NAACOS and 12 other leading health care groups sent a letter on June 15 expressing strong support for the measure. NAACOS will continue advocating to fix ACO benchmarking through our work with Congress and the Administration.
LAST CHANCE TO ATTEND BOOT CAMP ON ACO DATA NAACOS Boot Camp on Maximizing the Power of Data in Your ACO will take place virtually on June 22 and 23. Learn from leading ACOs how to turn your data into knowledge that will guide your operations and put your ACO on the path to success. Boot camp faculty will:
Answer the “Buy vs. Build” dilemma,
Review accessing and using basic ACO data,
Demonstrate how to close care gaps, and
Prepare your ACO to handle electronic Clinical Quality Measures (eCQMs).
Plus learn from ACO colleagues during three Zoom debrief sessions, held throughout the two-day boot camp.
This boot camp is designed for the ACO executive team, specifically executive directors, medical directors, population health leaders, and data/analytics teams. NAACOS ACO members save at least $200 per registration. Group rates also available to NAACOS ACO members.
NAACOS URGES NEW CMS ADMINISTRATOR TO MAKE ACO IMPROVEMENTS NAACOS recently sent a letter to the newly appointed CMS administrator, Chiquita Brooks-LaSure. In the letter, NAACOS urged CMS to consider policy changes to various ACO models and programs to strengthen the ACO movement and encourage broad participation in these models, including changes to the Pathways to Success requirements, Direct Contracting Model, and recent changes to quality changes to name several.
CMS UPDATES 2021 QUALITY BENCHMARKS Last week, CMS provided updated 2021 quality benchmarks due to a calculation error that resulted in significant changes resulting in the range of performance rates for a given decile shifting down one decile. According to CMS, this error affected every measure in the benchmark file. The updated benchmark files can be accessed on the CMS website.
CMS RELEASES ‘APP FOR ACOS GUIDE’ CMS has released a resource for Medicare Shared Savings Program (MSSP) ACOs entitled the ‘APP for ACOs Guide.’ This guide outlines quality reporting and scoring requirements under the Alternative Payment Model (APM) Performance Pathway (APP). Unfortunately, the guide leaves many unanswered questions regarding implementation of the new ACO reporting requirements under the APP. NAACOS has advocated for CMS to make additional guidance available to ACOs and will continue to push for changes to the APP requirements. More information on these requirements as they apply to ACOs is available in our member resource.
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MEDPAC RELEASES JUNE REPORT TO CONGRESS The Medicare Payment Advisory Commission (MedPAC) released its annual report to Congress on Medicare and the Heath Care Delivery System, which recommends that Medicare move toward a smaller, streamlined portfolio of alternative payment models (APMs). In a chapter focused on CMS’s portfolio of APMs, the commission highlights the challenges of model overlap when providers participate in multiple CMS APMs simultaneously. This can dilute financial incentives and make it difficult for evaluators to accurately address the impact of a model. While testing these models has given CMS valuable information about effective payment models, MedPAC asserts that continuing to test such a large number of models may hinder the ability of APMs to fully succeed. The commission recommends a refined portfolio of APMs that are designed to work together using consistent model parameters. NAACOS agrees that model overlap and complexity lead to challenges for model participants and evaluators, and NAACOS has advocated that when these challenges arise, deference should be given to total costs of care models such as ACOs. Another solution to minimize complexity and support APMs to reach their full potential would be to test innovations within ACOs.
FALL CONFERENCE ANNOUNCED: DATES, LOCATION, AND MORE! 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 Ave, 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. Marriott’s 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!
KEY APPOINTMENTS MADE TO CMS LEADERSHIP Following the confirmation of new CMS Administrator Chiquita Brooks-LaSure, the agency is filling out its new leadership team with those who are familiar with value-based care. Jon Blum is the new principal deputy commissioner at CMS. He held a similar position at CMS from 2009–2014 before leaving for private sector jobs. During his previous stint at CMS, Blum worked on the initial ACO regulations and other value-based care initiatives. Erin Richardson will be Brooks-LaSure’s chief of staff. She most recently worked as senior vice president and counsel at the Federation of American Hospitals and has other experience with value-based care initiatives.
INNOVATION CENTER FIXING ERROR IN DCE PAYMENT AMOUNTS The Innovation Center recently informed Direct Contracting Entities (DCEs) that it omitted some claims when estimating the capitation and Advanced Payment Option (APO) payments made to DCEs in April, May, and June of this year. The payment calculations for those months did not reflect claims in the lookback period billed under legacy TINs with providers participating in capitation/APO. As a result of the error, the capitation or APO payments made to DCEs may have been erroneously low.
To address the issue, CMS is recalculating the payment amounts, including the Total Care Capitation (TCC) withhold percentage, Base Primary Care Capitation (PCC) percentage, or APO per beneficiary per month (PBPM) amount (as applicable) for all DCEs that submitted legacy TINs on their final provider lists that include providers participating in capitation/APO. While the recalculation may increase a DCEs monthly payment amount, it will not result in a decreased monthly payment. The Quarter 3 Alternative Payment Arrangements (APA) reports that CMS plans to release in late June/early July will include the revised monthly capitation/APO payment amounts (and supporting calculations). Payments starting July 2021 will reflect this update, and any underpayments for April through June will be added to the July through September payments.
MSSP APPLICATION WINDOW NOW OPEN Phase One of the application submission period for the MSSP January 2022 start date is now open, with applications due on June 28, 2021 by 12:00 pm ET. Despite NAACOS advocacy, application windows have not been extended by CMS. ACOs are only eligible to apply if they submitted a Notice of Intent to Apply (NOIA) by June 7, 2021. However, ACOs that submitted a NOIA are not required to continue with the application process. The last day to add ACO participant TINs and/or skilled nursing facility affiliates is August 3, 2021, and the last day to remove participants is September 10, 2021. As a reminder, these dates are still subject to change. More details about the application timeline and an application toolkit are available.
CONGRESS CONTINUES INFRASTRUCTURE NEGOTIATIONS This week congressional negotiators continue to work through various proposals on infrastructure spending. The core pieces of the deal, however, are still being worked through, and stakeholders are not confident that the final measure will receive bipartisan support (which is not necessarily needed for passage under reconciliation). While majority leadership had set a summer deadline for legislative action on the plan, it appears more likely that a measure will be passed this fall after the August recess. The prospect for health care items being included remains low. Drug pricing continues to be a hot topic on Capitol Hill, but it is currently considered unlikely that drug pricing legislation will move as a standalone measure or be included in an overall infrastructure plan.
VIEW OUR MODEL MATRIX WEBINAR SERIES ON-DEMAND In case you missed either or both parts of NAACOS’ revived Navigating the Model Matrix webinar series, you can catch them on demand. The 101 webinar provided a high-level review of key CMS Innovation Center models and drew comparisons to previous, legacy models, including the MSSP. The 201 webinar 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 RELEASES QUALITY PROGRAMS ASSESSMENT Every three years as required by section 1890(a)(6) of the Social Security Act, CMS releases an assessment of the measures used across its quality programs. The 2021 report includes findings from 26 programs, including the MSSP. Specifically, the number of measures across CMS was reduced by 24 percent and outcome measures increased from 39 percent to 46 percent in the last five years with 80 percent of the existing measures considered digital and half being calculated using all-payer data. The report also determined that 91 percent of the measures with at least three years of data between 2013 and 2018 led to at a minimum, stable or improved performance rates. In addition, when reviewing the impact of 15 key indicator measures, CMS estimates a cost savings between $29.6 billion to $51.9 billion in 2018 dollars. Additional information such as the impact of the measures in addressing disparities in care and perceived meaningfulness of key indicator topics to patients, caregivers, and providers is included as well as appendices with measure-specific information by program.
DEADLINE APPROACHES FOR DIRECT CONTRACTING DCEs interested in participating in an optional second Implementation Period (IP2) must have a provider list submitted through 4i by June 30 to dictate which providers can conduct voluntary alignment. This IP2 is primarily for Next Generation (Next Gen) ACOs who didn’t have an opportunity to participate in the first IP that ended in March. IP2 will begin August 1 and run through December 31, 2021. Applications from Next Gen ACOs interested in participating in the Global and Professional Direct Contracting (GPDC) Model next year were due on June 14. All DCEs interested in updating the provider lists for 2022 can start making changes on July 1.
ACO LEADERS APPOINTED TO MEDPAC Last week, the U.S. Government Accountability Office (GAO) appointed members to the Medicare Payment Advisory Committee (MedPAC). Notably, Founder and Executive Chairwoman of NAACOS member Caravan Health, Lynn Barr was appointed for a three-year term. Additionally, Jonathan Jaffrey, Professor of Medicine at the University of Wisconsin School of Medicine and Public Health, who also runs the university’s ACO, was appointed. Other appointments included Jaewon Ryu, Geisinger Health System; Jonathan Perlin, HCA Healthcare; and Marjorie Ginsburg. MedPAC has worked to analyze access to care, cost and quality of care, and other key issues affecting Medicare since 1997. NAACOS is pleased to see ACO voices represented in advice to Congress on payments to providers in Medicare’s programs.
CMS PROVIDES UPDATED VOLUNTARY ALIGNMENT FACTSHEET CMS recently provided ACOs with an updated voluntary alignment fact sheet for beneficiaries. These updates are a result of changes made to the Medicare.gov website, which patients must use to select a provider for purposes of voluntary alignment. Patients can access the directions for selecting a provider for voluntary alignment on the ‘find and compare health care providers’ page of medicare.gov. The updated fact sheets in English and Spanish are available to ACOs in the Marketing Toolkit of the Knowledge Library tab in the ACO-Management System.
2021 MIPS PROMOTING INTEROPERABILITY HARDSHIP Applications for 2021 Merit-based Incentive Payment System (MIPS) Promoting Interoperability Performance Category hardship exceptions and extreme and uncontrollable circumstances exceptions are now being accepted by CMS. The deadline to apply is December 31, 2021. Practices in an ACO that apply and are approved for such exceptions will be removed from the calculation of the overall weighted average ACO score for the Promoting Interoperability Performance Category. To apply, access the Quality Payment Program (QPP) website and navigate to the ‘exceptions applications’ on the left to select Promoting Interoperability Hardship.
THE LAN CONVENES A HEALTH EQUITY ADVISORY TEAM Earlier this month, the Health Care Payment Learning and Action Network (LAN) established a Health Equity Advisory Team (HEAT) to identify and prioritize opportunities to advance health equity through APMs. The goal of the HEAT is to leverage APMs to make care more accessible, improve patient outcomes, and reduce disparities. The HEAT will be co-chaired by Dr. Marshall Chin of the University of Chicago and Karen Dale of AmeriHealth Caritas. This multistakeholder effort provides a unique opportunity to address health equity in payment and delivery system models. You can stay connected with their work by signing up for the LAN Newsletter.
INVITATION TO ROUNDTABLE ON IMMUNIZATION AND COMMUNITIES OF COLOR The Demonstrating Real Improvement Value in Equity (DRIVE) Program is brought to you by the National Minority Quality Forum’s (NMQF’s) Center for Sustainable Health Care Quality and Equity (SHC). Join NMQF, one of the nation’s leading health equity organizations, along with vaccine and health system leaders Drs. Greg Poland and Saria Saccocio, on June 21 from 2:00 to 3:30 pm ET in a discussion about influenza immunization in the 2021–2022 season and racial/ethnic equity. To participate, contact SHC President, Dr. Laura Lee Hall at llhall@nmqf.org.
