MEETING OF MEMBERS: ACO AND DCE MEMBERS REGISTER NOW! The 2021 Annual Membership Meeting session is scheduled for November 4 at 2:00 pm ET. Register for this hour-long session to gain a firsthand look at the state of NAACOS, its membership composition, new resources, and most importantly what we’re doing to support and advocate for ACOs and DCEs in 2022 and beyond. The live webinar is for ACO and DCE members only and is not open to Business or Alliance Partners. We look forward to seeing you there! And don’t worry if you cannot attend the live event; members and partners will be able to access the recordings the following day on NAACOS’ on-demand webinar pages and, therefore, enjoy at their leisure.
CMS WHITE PAPER OUTLINES INNOVATION CENTER GOALS AND OBJECTIVES NAACOS is pleased to see that one of our key policy goals for the Biden administration is included in a new white paper published this week from the CMS Innovation Center. That paper, which details a vision for the Innovation Center over the next 10 years, calls for every Medicare beneficiary to have a relationship with a provider accountable for quality and total cost of care by 2030. NAACOS raised a similar goal to greatly enhance the number of beneficiaries in ACOs in a letter this summer to CMS Administrator Chiquita Brooks-LaSure. Other goals laid out in the paper include better addressing health equity, affordability, and multi-payer models. NAACOS issued a statement yesterday in support of the paper, and we will continue to work with CMS leaders to advance our shared goals and advocate for the continued advancement of accountable care models.
HHS EXTENDS COVID-19 PHE FOR ANOTHER 90 DAYS Last week, HHS Secretary Xavier Becerra extended the COVID-19 Public Health Emergency (PHE) by another 90 days to last through January 16. It was due to expire Monday. A number of Medicare polices are tied to the PHE, including CMS waiving shared losses for ACOs and broad application of telehealth waivers. More information on COVID-19 is available. CMS is also updating these Frequently Asked Questions on Medicare Fee-for-Service billing, which has an entire section on the Medicare Shared Savings Program (MSSP).
NAACOS ADVOCATES FOR PRE-PANDEMIC YEARS AS BENCHMARK OPTION IN 2022 NAACOS and 12 other leading healthcare associations and stakeholder organizations recently submitted a letter to CMS Administrator Chiquita Brooks-LaSure asking that ACOs be allowed the option to select pre-pandemic years on which to base benchmarks, citing fairness in the way performance is measured in light of the global pandemic. In an analysis conducted by the Institute for Accountable Care, 45 percent of ACOs entering a new contract in MSSP next year would be harmed under current policy, which includes using 2019–2021 as the three baseline years in a benchmark. This includes more than 10 percent of those ACOs that are set to see their benchmarks rise by more than 3 percent because of the inclusion of pandemic-stricken years. Instead, CMS should give ACOs the option to use pre-pandemic years of 2017–2019 if they so choose for agreements beginning in 2022. NAACOS also had a meeting with CMS to discuss our recommendation. NAACOS issued a press release on the letter and will alert members to any change in CMS policy.
NAACOS RELEASES RESOURCE ON ACCESSING ECQM SPECIFICATIONS MSSP ACOs have two quality reporting options for 2021: report via Web Interface, or report via electronic clinical quality measures (eCQMs)/Merit-based Incentive Payment System (MIPS) CQMs. ACOs electing to report via eCQMs must utilize eCQM reporting specifications which differ from Web Interface reporting specifications. While Web Interface reporting specifications have been packaged for ACOs, eCQM specifications must be accessed through multiple websites. NAACOS has developed a guide to assist ACOs in accessing these specifications. This document will allow ACOs to understand how to access narrative measure statements for numerators/denominators, specifications, and data elements, as well as any release notes. For more information on eCQM requirements for ACOs, access our quality resource reviewing 2021 and 2022 quality changes. Please note that CMS has proposed changes to these requirements in the 2021 proposed Medicare Physician Fee Schedule Rule, and a final regulation is anticipated in early November. NAACOS will update quality resources for members when the final rule is released.
CMS CLARIFIES POLICIES AROUND MEDIA INQUIRIES TO ACOS Following NAACOS advocacy, CMS clarified that ACOs do not need to have answers to questions from members of the media reviewed by CMS. NAACOS received word from an ACO member who asked the MSSP help desk if responses to press inquiries needed CMS approval. The ACO was told yes and that media inquiries need to be handled the same way as other marketing materials. This was troubling to us as it would stifle a healthy dialogue with the press, so we reached out to CMS leadership for clarification. The agency replied that CMS does not need to approve questions from news reporters, journalists, or the press and CMS is following up to make sure agency contractors and staff know they don’t review ACO press inquiries/responses. NAACOS hopes this misinformation wasn’t given to more ACOs and wanted to let our members know about this important clarification.
UPDATED NAACOS RESOURCE ON APM MODEL OVERLAP POLICIES As CMS and its Innovation Center continue to build on the diverse portfolio of Medicare payment initiatives, NAACOS continues to advocate for a comprehensive model overlap policy that prioritizes total cost of care initiatives, such as MSSP and Direct Contracting. In the meantime, NAACOS has updated its resource detailing the current policies for provider and beneficiary overlap across initiatives.
NAACOS HOSTING ITS NEXT DIRECT CONTRACTING LEARNING DISCUSSION The next Direct Contracting Learning Discussion is scheduled for this afternoon, and we welcome current, future, and potential DCEs to share your feedback, questions, concerns, and points of interest. This is intended to be a collaborative discussion and a forum for shared learning, and we ask that you come prepared to share your perspectives and react to issues at hand. The meeting will start at 2:00 pm ET and take place over Zoom (passcode: 424162). Advance registration is not required. If you have issues you’d like to raise, please share them with DirectContracting@naacos.com. For those unable to attend the October 21 Direct Contracting Learning Discussion, the recording will be available online along with all of our other Direct Contracting resources.
DEMOCRATS CONTINUE TO NEGOTIATE ON SPENDING BILLS For the first time in weeks, Democrats are making significant progress towards agreement on a reconciliation package. President Biden has met with key policymakers over the past several days and outlined his desired package: an approximately $2 trillion bill that would include childcare tax credits, home health, and universal pre-K. Climate change measures may also be included. It is unclear what will happen with Medicare expansion of dental and other benefits.
NAACOS COMMENTS ON HOW ACOS CAN HELP ADDRESS SDOH This week, NAACOS submitted comments in response to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) Request for Information (RFI) on social determinants of health (SDOH) and health equity within the context of Alternative Payment Models (APMs) and Physician-Focused Payment Models (PFPMs). Committee members sought information about current perspectives on how addressing SDOH and equity can help to optimize health care delivery and value-based transformation. In comments, NAACOS highlighted the importance of improving health equity in order to deliver high quality care in a cost-effective manner. NAACOS also shared some of the unique challenges faced by ACOs in addressing SDOH and improving health equity, including data and interoperability issues and lack of funding and resources to implement SDOH and health equity initiatives. Recommendations included upfront funding and adjustments to financial benchmarks to support this work, cross-sector collaboration to develop new standards for data collection and interoperability, changes in quality measurement, and alignment of current policies to facilitate data sharing and care coordination.
NEW CMS MIPS RESOURCES AVAILABLE CMS recently provided new MIPS resources to further explain Quality Payment Program payment adjustments and performance feedback, as well as the new extended targeted review available for 2020 MIPS scores. Access the new FAQs and targeted review guide for additional information. As a reminder, the deadline to submit a targeted review for 2020 MIPS scores is November 29. Finally, CMS also provided guidance on the 2021 MIPS Extreme and Uncontrollable Circumstances (EUC) policy for clinicians affected by natural disasters during the 2021 performance period. MSSP, Next Generation ACOs and DCEs can submit an EUC application on behalf of their MIPS eligible clinicians. Refer to page 12 in this guidance for additional information.
