NAACOS Newsletter for Members and Partners November 05, 2020
| POST-ELECTION ANALYSIS: DON’T MISS THE NAACOS WEBINAR While Joe Biden has an electoral lead over President Donald Trump, there will be recounts or legal changes that will delay a final outcome. Democrats are projected to retain control of the House but will not expand their majority, despite predictions of a possible blue wave election. The chances of Democrats taking control of the Senate were also greatly diminished after several vulnerable Republican incumbents successfully won reelection against well-financed Democratic challengers. Although a handful of Senate races are still too close to call, final control of the Senate may not be determined until January if both Georgia Senate races head to a runoff election. NAACOS will host an hour-long webinar on November 11 from 2:00 to 3:00 pm ET that will focus on how this year’s election will affect health care in 2021 and beyond. The webinar will provide an overview of election results, outlook for this year’s lame duck session of Congress, anticipated priorities for the 117th Congress, overview of the legal challenge to the Affordable Care Act, and agency health care priorities. Register today! TRANSPARENCY FINAL RULE RELEASED CMS recently released a Transparency in Coverage final rule, aiming to give consumers more information on pricing information for health plans. The rule goes into effect January 1, 2021 and will make certain pricing information publicly available starting in 2022 for items such as in network prices, out of network prices and certain drug pricing. CMS has released a press release and fact sheet on the final regulation. REGISTER TODAY FOR WEBINAR — DCE AND ACO TOOLKIT FOR TAKING RISK To help ACOs and newly formed DCEs navigate the challenging healthcare landscape of today and successfully manage risk while improving patient outcomes, Episource will deliver a webinar, “DCE and ACO Toolkit for Taking Risk.” Presenters from Episource will include:
NAACOS WRITES CMMI WITH CHANGES TO RURAL-FOCUSED ACO MODEL NAACOS recently sent a letter to CMS Innovation Center (CMMI) Director Brad Smith asking for several improvements to the ACO Transformation Track of the Community Health Access and Rural Transformation (CHART) Model. The model will offer participants upfront funding to join MSSP if a majority of their ACO providers operate in rural areas. Specifically, we asked that the agency allow current MSSP ACOs to apply, address MSSP’s “rural glitch,” which counts ACO-assigned beneficiaries in the regional population, allow more than 20 ACOs to join, reduce MSSP’s minimum beneficiary requirement, and allow broader use of waivers. CMS has said to expect a request for Application for the ACO Transformation Track in early 2021. CMS POSTS PRELIMINARY 2019 QPP RESULTS CMS recently released limited performance results from the 2019 Quality Payment Program (QPP). Some ACO/APM highlights include:
CONTACT YOUR LAWMAKERS ABOUT THE QP THRESHOLD NAACOS continues to prioritize preventing rising QP thresholds, which must be met to receive the 5 percent Advanced APM participation bonus and will increase to unrealistic levels in 2021. NAACOS is working hard to correct the issue this year but needs your help. Please take a few minutes to visit our Take Action page and write your elected representatives in Congress to tell them to take action. We’ve drafted a letter to get you started, which should be edited to include details about why this issue is important to you. Don’t forget to add your ACO’s name at the bottom before submitting the letter. DIRECT CONTRACTING ANNOUNCES IMPLEMENTATION PERIOD PARTICIPANTS NAACOS welcomes the 51 organizations participating in Direct Contracting’s Implementation Period. These Direct Contracting Entities (DCEs) have beneficiaries in 39 states and the District of Columbia and Puerto Rico. This initial Direct Contracting cohort demonstrates strong interest in this new model. These initial participants should be commended for their commitment to improving the quality of care for Medicare patients while lowering spending. Direct Contracting is the next premier accountable care model from the CMS Innovation Center and seeks to build on the successful Next Generation ACO Model, while redesigning healthcare delivery and payment. Direct Contracting’s Implementation Period will allow organizations to sign up beneficiaries, build a history of claims data, and establish care coordination practices before financial accountability starts in April 2021. Get more information on these participating DCEs.  DON’T MISS NAACOS DIRECT CONTRACTING RESOURCES All three webinars from our October series breaking down the financial specifications of Direct Contracting are available on-demand for NAACOS and Direct Contracting Taskforce members. The three help DCEs understand the benchmarking and risk adjustment policies for Standard, New Entrant, and High Needs Population DCEs. We’ve also developed a summary of the recently released financial specification papers from CMS. Lots more information and updates are available on our stand-alone Direct Contracting page. CMS RELEASES CJR TECHNICAL CHANGES FOR COVID-19 CMS released an Interim Final Rule with Comment (IFC) modifying certain policies for the Comprehensive Care for Joint Replacement (CJR) Model to account for COVID-19, among other items. Through this regulation, CMS is extending Performance Year (PY) 5 by adding six additional months, creating an episode-based extreme and uncontrollable circumstances COVID-19 policy, and providing two reconciliation periods for PY 5. Additionally, CMS is adding Diagnoses Related Groups (DRGs) 521 and 522 for hip and knee procedures for the model. This follows changes made to the model due to COVID-19 in the April 2020 IFC released earlier this year. The Innovation Center has created a resource outlining the various model updates made for the COVID-19 Public Health Emergency (PHE). NOVEMBER 13 LAST DAY TO REQUEST 5 PERCENT ADVANCED APM BONUS On September 28, CMS published an updated list of unpaid QPs. These clinicians were not provided payment for the 5 percent Advanced APM bonus due to insufficient banking information. This could include certain physician assistants (PAs). ACOs should encourage practices to check the list to ensure providers listed request their payments from CMS by the November 13 deadline. CMS instructs providers to complete the necessary banking forms and submit them to the Quality Payment Program (QPP) Help Desk at [email protected], no later than November 13, 2020. LETTER URGES CMS TO RELEASE SUD CLAIMS TO ACOS NAACOS is asking HHS to begin releasing claims data on substance use disorder (SUD) to ACOs. In the letter, we state that we believe the passage of the Coronavirus Aid, Relief, and Economic Security (CARES) Act earlier this year should resolve any lingering doubt that sharing of this data is allowed. Section 3221 of the CARES Act modernizes the privacy of treatment records for SUD by creating parity between 42 CFR Part 2, which governs SUD privacy, and the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The CARES Act and congressional intent to expedite SUD data sharing is clear, and ACOs should have access to this data. RADIATION ONCOLOGY MODEL DELAYED Responding to push back from stakeholders, CMS will delay the start of a mandatory Innovation Center model around radiation oncology payments by six months. It was set to start on January 1 but will now start on July 1. The model will be testing paying site-neutral, episodic payments based on patients’ cancer diagnosis that cover radiotherapy services furnished in a 90-day episode for 16 cancer types. The End-Stage Renal Disease (ESRD) Treatment Choices Model (ETC Model), which CMS finalized in a rule in September, is still scheduled to start on January 1. CMS PUBLISHES 2022 MA AND PART D ADVANCE NOTICE CMS is predicting that Medicare Advantage (MA) plans will see a roughly 2.82 percent increase in revenue in 2022 under a proposed Advanced Rate notice. CMS proposes to apply a coding pattern adjustment of 5.9 percent, which is the minimum adjustment for coding pattern differences between Medicare Advantage and Traditional Medicare required by the statute. For 2022, CMS is proposing to use only encounter data for risk adjustment purposes and fully phase in the 2020 CMS-Hierarchical Condition Categories Risk Adjustment Model. CMS is releasing its 2022 notice three months earlier than usual to give MA organizations more time to prepare their bids due to the pandemic. The fact sheet and rate notice are available online. ANNUAL CERTIFICATION PERIOD OPEN THROUGH MONDAY MSSP ACOs have until noon ET on November 9 to review, certify, and electronically sign documents related to their participation in PY 2021. ACOs approved for a Skilled Nursing Facility (SNF) Three-Day Rule Waiver will need to sign additional documentation. All currently participating ACOs and certain terminating ACOs must review, certify, and electronically sign documents. ACOs must log into the ACO Management System to review and sign their annual certification documents. HHS DELAYS DATA BLOCKING RULE HHS is delaying by six months a final rule that aims to make it easier to share patients’ health records and data among providers, plans, and patients. Many requirements that were to take effect on November 1 will now take effect on April 5, 2021. HHS cited the ongoing pandemic and giving the healthcare system more time to comply with the new rules as the reason for the delay. HHS published an interim final rule with comment period and press release on the delay. This NAACOS resource summarizes the new rules for ACOs, which outlines exceptions from “information blocking,” with the expectation that those in health care must share patient information with others unless one of eight exceptions are met. The final rules promote care coordination through better information sharing and should help the work of ACOs. |