NAACOS Newsletter for Members and Partners May 06, 2021
| NAACOS AND OTHERS URGE CMS TO DELAY, MODIFY MSSP QUALITY OVERHAUL NAACOS and 10 other leading health care associations sent a letter to Xavier Becerra, Secretary of the Department of Health and Human Services (HHS), expressing significant concerns with aspects of the Medicare Shared Savings Program (MSSP) quality overhaul and urging reform. The letter and accompanying press release feature data and feedback from a recent NAACOS ACO survey on the MSSP quality overhaul. The survey results and letter emphasize the high level of concern around the MSSP quality changes and urge swift action by the administration to:
ACO CALL TO ACTION: TELL HHS TO FIX ACO QUALITY EVALUATIONS As noted in the article above, NAACOS is ramping up advocacy efforts on the MSSP quality overhaul. The quality changes were finalized in late 2020 through the 2021 Medicare Physician Fee Schedule, and they are summarized in this NAACOS analysis and resource. To help call attention to challenges related to the MSSP quality overhaul, including the mandatory use of eCQMs and MIPS CQMs in a little over six months and the requirement for ACOs to report on all-payer data, we need your help. HHS and CMS must hear directly from ACOs on these issues. To help you send a message advocating for ACO quality changes, please visit our Take Action page today! CMS DROPS TWO MSSP CLAIMS-BASED MEASURES FOR PY 2020 CMS recently announced that two administrative claims-based measures in the MSSP are re-designated to pay-for-reporting rather than pay-for-performance for Performance Year (PY) 2020. The two measures are:
 REGISTRATION OPEN FOR JUNE BOOT CAMP ON ACO DATA Harnessing your data can create actionable strategies that improve your ACO’s performance. Bring your team to a virtual training on Maximizing the Power of Data in Your ACO 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:
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. Register now and get data to work for you! CONGRESS FACES STACKED AGENDA Majority leadership in the House and Senate have been tasked with advancement of President Biden’s American Jobs and Families Plans, while at the same time responding to growing calls for Affordable Care Act (ACA) expansion and drug pricing measures, which were largely not included in the Plans. Members are also focused on broadband and telehealth, which were the subject of deliberation in the House last week during a House Ways and Means Committee hearing — see NAACOS’ statement on the hearing. Notably, the New Democrat Coalition is proposing focus on value-based care, calling for continued efforts to support value-based care in a recent letter to the President. As Speaker Pelosi’s deadline of early summer draws near for House action on the American Jobs and Rescue Plans, Congress is likely to coalesce around a set of measures that can pass under a tight Senate majority. REGISTER NOW FOR UPCOMING WEBINAR ON IN-NETWORK UTILIZATION In response to multiple requests on the NAACOS listserv, we have scheduled a webinar on In-Network Utilization. Join us on May 19 from 1:00 to 2:00 pm ET to learn from ACO peers about their goals and best practices. The Institute for Accountable Care will also share new data on national trends. Speakers will give brief presentations allowing ample time for participants to engage with one another. Plan to bring your questions and own examples. Speakers include:
 CMS PROPOSES TO FREEZE PATHWAYS GLIDE PATH ADVANCEMENT IN 2022 In a proposed hospital payment rule published last week, CMS proposed to allow Basic Track ACOs the option to forgo automatic advancement along the MSSP glide path for PY 2022. If finalized, an eligible ACO may elect to remain in the same level of the Basic Track’s glide path in which it participated during PY 2021. However, an ACO that elects this advancement deferral option would be automatically advanced to the level of the Basic Track’s glide path it would have participated in during PY 2023. CMS had installed a similar option to freeze movement along the glide path between 2020 and 2021. ACOs can still progress along the glide path or jump to a higher level of risk in 2023. Importantly, CMS later clarified that ACOs still in legacy MSSP tracks, such as Track 1, 2, 3, and 1+ must apply to enter MSSP’s Pathways to Success structure for 2022. NAACOS views this proposal very positively and advocated for something similar. However, we also advocated that CMS not place ACOs in the risk track they would have been scheduled to enter in 2023 had they not opted to freeze movement. More information on flexibilities provided by CMS last year can be found in the NAACOS analysis of an important interim final rule with comment period. Elsewhere in the proposed 2022 Medicare Hospital Inpatient Prospective Payment System and Long Term Care Hospital Rule, CMS proposed to repeal the requirement that hospitals report their median payer-specific negotiated charges they negotiated with all of their Medicare Advantage plans, starting in 2021. CMS also proposed to extend the new add-on payments for COVID-19 treatments through the end of the fiscal year in which the COVID-19 PHE ends. There were additional proposed changes to ensure COVID-19 does not harm hospitals’ performance in the Hospital Readmissions Reduction Program, Hospital-Acquired Conditions Reduction Program and Hospital Value-Based Purchasing Program. Overall, CMS projects hospitals would see about a 2.8 percent increase in reimbursement because of the proposed rule. Additional information on the proposed rule can be found in this CMS fact sheet. APPLICATION INFORMATION TO JOIN MSSP IN 2022 UPDATED BY CMS CMS recently provided updated information on the MSSP application process for the January 1, 2022, start date. The agency notes that this updated process was designed to give ACOs additional time to submit materials. Notice of intent to apply (NOIA) is due by 12:00 pm ET on June 7, 2021. Following this, the application window opens. The first step of this two-step application process, due June 28, 2021, at 12:00 pm ET, will include submission of the ACO Participant List and Skilled Nursing Facility (SNF) Affiliate List and draft repayment mechanism documentation. The second step, due October 19, 2021, at 12:00 pm ET, will include submission of all other application materials such as organizational chart and attestations. It is important to note, these dates are still subject to change. More information about the application process is available. CMS UPDATES COVID-19 HOSPITALIZATION, COST DATA FOR MEDICARE Traditional Medicare beneficiaries hospitalized with COVID-19 cost an average of $23,587 per stay. Of the nearly 655,000 COVID-19 hospitalizations across Medicare, 53 percent were a week or less. CMS revealed these numbers in an updated snapshot of COVID-19’s impact on Medicare, including chronic disease prevalence among COVID-hospitalized patients, where patients were discharged to, and demographic and age information. To date, there have been more than 3.8 million cases among Medicare beneficiaries and more than 1 million hospitalizations. The updated snapshot covers the period from January 1, 2020, to February 20, 2021. It is based on Medicare Fee-for-Service claims and Medicare Advantage encounter data CMS received by March 19, 2021. |
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| COVID-19 VACCINE INFORMATION IN QUARTERLY UTILIZATION REPORTS MSSP will add a flag to quarterly Beneficiary Expenditure Utilization Reports to denote that Medicare has a COVID-19 vaccination claim for the ACO’s assigned beneficiary. This indication will be effective beginning with Quarter 1 2021 reports. The agency notes that Medicare claims data for vaccinations is not comprehensive and the lack of a vaccine claim does not mean the beneficiary has not received a COVID-19 vaccination. ACOs’ monthly Medicare Claim and Claim-Line Feed (CCLF) files also indicate if Medicare has a claim for a beneficiary for COVID-19 vaccine administration. The vaccination information can be used as a starting point for vaccination discussions with patients. The agency encourages ACOs to analyze the vaccination status of beneficiaries by race, ethnicity, preferred language, disability status, and dual eligibility to identify disparities and target outreach strategies. CMS RELEASES CASE STUDY ON BUILDING COMMUNITY PARTNERS TO ADDRESS SDOH The CMS Innovation Center released a new case study on addressing social determinants of health (SDOH). Health Net of West Michigan established an advisory board made up of community partners across sectors who meets quarterly discuss addressing social determinants of health at the community and systems levels and involving community advisors. Health Net is a participant in the Innovation Center’s Accountable Health Communities Model, which strives to address gaps between clinical care and community services by testing whether identifying and addressing the health-related social needs of Medicare and Medicaid beneficiaries’ through screening, referral, and community navigation services will impact health care costs and reduce health care utilization. NAACOS COMMENTS ON HIPAA PROPOSED RULE In comments filed in response to a proposed rule that would make changes to the Health Insurance Portability and Accountability Act (HIPAA)Privacy Rule, NAACOS called on HHS to acknowledge the growing importance of ACOs and population-based payment models. NAACOS called on HHS to allow patient information to be shared with community-based organizations at the population level, not just individual as proposed, in order to facilitate care coordination and case management. While HHS proposed to change the definition of health care operations to encompass all care coordination and case management by health plans, NAACOS believes HHS should clarify that this change applies not only for health plans, but also for ACOs. NAACOS full comments are available.  NAACOS SUBMITS STATEMENT FOR THE RECORD ON FUTURE OF TELEHEALTH In a letter to the House Ways and Means Health Subcommittee last week, NAACOS urged Congress to look to ACOs as a way to expand the use of telehealth in a cost-effective manner that ensures quality. We argue that since ACOs take accountability for patients and are increasingly at financial risk for their spending and quality, they should be granted waivers on telehealth’s use. To date, waivers exist for just two-sided ACOs that use prospective assignment. Making permanent the telehealth waivers put in place during the COVID-19 PHE remains an important goal of NAACOS’. We will continue to press Congress on using ACOs as an avenue for wider telehealth coverage. More information on what telehealth services are allowed during the PHE is available. More detail on NAACOS telehealth stance is available in these policy principles. CJR MODEL EXTENDED BY THREE YEARS On April 29, 2021, CMS issued a final rule extending the Comprehensive Care for Joint Replacement (CJR) Model by three years, through December 31, 2024, and making other changes. Most notably, CMS is eliminating the voluntary participation option during the extension and adding outpatient joint replacements to the program by removing total hip arthroplasty (THA) and total knee arthroplasty (TKA) from the inpatient-only list. The rule also changes how target bases are calculated, from using three years of historical data to the single most recently available year of baseline claims data, and risk adjusting the target price calculations. Other changes to the model include eliminating the gainsharing cap, changing the quality adjustment methodology, and revising the high-episode spending cap and target price adjustment for regional market trends. The CJR model tests bundled payment and quality measurement for episodes of care associated with hip and knee replacements, the most common inpatient surgeries for Medicare beneficiaries. Read more about the model. NEW WEBINAR: IMPROVING CARE FOR HIGH-NEED ELDERS THROUGH THE CAPABLE MODEL The Community Aging in Place—Advancing Better Living for Elders (CAPABLE) Model is a home-based intervention, developed at the Johns Hopkins School of Nursing, that helps low-income seniors safely age in place. The approach teams a nurse, an occupational therapist and a handyman to address the home environment and improve the independence of older adults. Multiple studies have shown that CAPABLE has successfully reduced patients’ functional limitations and lowered their healthcare spending. Organized by the Institute for Accountable Care, this webinar will take place on May 25 at 2:00 pm ET and feature Alice Bonner, CAPABLE’s Director of Strategic Partnerships, who will review key aspects of the model, summarize evidence of effectiveness, and explore how this intervention can be integrated into existing programs to support high-need beneficiaries. If you are interested in attending, please send your contact information to [email protected]. |