NAACOS Newsletter for Members and Partners September 09, 2021

Table of Contents
Attend the Fall Conference, In Person or Online
Free Webinar on September 14: Partnering with GEDs
Share Your Feedback with CMS On Proposed 2022 MPFS Rule
Congress Begins a Busy September
Deadline to Remove ACO Participants and/or SNF Affiliates
Honoring Theresa Knowles, Quality Committee Member
CMS Releases PY 2022 Financial Papers for GPDC Model
Next Direct Contracting Learning Discussion Set for September 15
Deep Dive of 2020 MSSP Results
Update MSSP ACO Public Reporting Template by September 24
New APP Quality Resources Available for ACOs
2021 Medicare Trustees Report
Evaluation of Vermont APM Shows Positive Results

ATTEND THE FALL CONFERENCE, IN PERSON OR ONLINE
Registration is open for the in-person and virtual options! In-person attendees must be fully vaccinated for COVID. Those unable to attend in person can participate in the live webcast of the conference. The live webcast includes all breakout sessions and plenaries as well as the sponsored sessions. Live webcast participants also receive six months of access to the recordings of the sessions so that you don’t miss any sessions! Please note, the live webcast does not include any of the pre-conference workshops. We also have group rates available for both in-person and virtual. Contact Emily Perron for more information.

If you are able to attend in person, don’t miss our highly valuable pre-conference workshops held concurrently on Wednesday, September 29 from 1:00–4:00 pm ET. These will not be available virtually and require separate registration from the main meeting. Add one of the following workshops to enhance your conference learning!

Improving Care for Duals in Your ACO Chair: Bob Sarkar, Arkansas Health Network, LLC
  • Caring for high-need, high-risk patients
  • Applying elements of the CareMore model
  • Using dual population to expand more into Medicaid
  • Learning from D-SNPs and I-SNPs to inform care
  • Working with states to align value-based care across Medicare and Medicaid
Succeeding with Medicare Advantage Contracts Chair: Erin Smith, Aledade ACO
  • Medicare Advantage (MA) basics: what plans enter, how are plans paid, why would a patient choose MA over Medicare FFS, the importance of STARs vs RAF
  • Understanding the MA payer landscape
  • How plans think about partnering with providers
  • Strategies to negotiate an MA ACO agreement
  • Importance of RAF vs STARs
  • Implementation considerations and keys to success: needed systems, frequency of feedback discussion with payer, the importance of data, and MSSP vs MA practice transformation

Welcome New Business Partners

Aon
We are a leading global professional services firm providing a broad range of risk, retirement and health solutions.
aon.com
MedVision
MedVision provides QuickCap (QC7), an administrative platform to manage the varied departmental processes of delivery models in risk-based / payer-like organizations.
medvision-solutions.com
Brilliant Care
BrilliantCare is an innovative population health management company focused on enhancing the ability of healthcare practitioners to provide optimal and augmented care to their patients while reducing the total cost-of-care.
brilliant.care
Reemo Health
Reemo Health is a connected health company specializing in home-based care management technology for high-risk and older adult patients.
reemohealth.com
Healthjump
Healthjump is a cloud-based software platform for managing the collection, storage, and movement of clinical and financial data between practice EHRs, applications, and healthcare organizations.
healthjump.com
 

FREE WEBINAR ON SEPTEMBER 14: PARTNERING WITH GEDS
More than 200 U.S. emergency departments are now certified as Geriatric Emergency Departments (GEDs) that strive to identify care gaps and unaddressed health needs that could result in repeated readmissions and to effectively transition patients to appropriate outpatient settings when inpatient services are not indicated. Partnerships between ACOs and GEDs could reduce preventable acute care services and improve outcomes for elderly patients with complex needs. On September 14 at 2:00 pm ET, NAACOS will hold a webinar to provide an in-depth look at the capabilities and structure of GEDs and explore opportunities for partnerships with ACOs. Registration is free for NAACOS ACO members and business partners. Register now!

SHARE YOUR FEEDBACK WITH CMS ON PROPOSED RULE
NAACOS has drafted a detailed comment letter in response to the proposed 2022 Medicare Physician Fee Schedule (MPFS) Rule. This regulation includes many provisions affecting Medicare Shared Savings Program (MSSP) ACOs, including proposed changes to quality reporting requirements, discussion of fixing benchmarking and risk adjustment flaws, updates to patient assignment codes, improvements to repayment mechanism requirements and more. Read our member analysis of the rule and respond to CMS by sharing your feedback prior to the September 13 deadline. It is critical that CMS hear directly from ACOs as the agency will carefully consider how many ACOs weigh in on a particular issue and what their specific feedback is. Members can use NAACOS’ Take Action to send a brief letter focusing on a few key proposals related to MSSP quality reporting and financial benchmarks. NAACOS has drafted the letter to get you started, and ACOs are encouraged to personalize it. Or members can send a longer, more detailed comment letter to the agency via the regulations.gov website. Please feel free to incorporate any or as much text as you want from our draft letter. Thank you for your advocacy engagement, which will support ACOs and the shift to value-based care!


CONGRESS BEGINS A BUSY SEPTEMBER
Congressional Democrats are pushing to advance President Biden’s “Build Back Better Plan” this month, with upcoming self-imposed deadlines to complete legislative language by September 15 and conduct floor activity on the infrastructure component by September 27. NAACOS is advocating to include the Value in Health Care Act (H.R. 4587) in the broader package and encourages ACOs to visit Take Action to send a letter to lawmakers urging their support.

Last week, though, Senator Joe Manchin raised doubt for the probability of the entire proposal to advance, as the Senator published an Op-ed in the Wall Street Journal stating that he would not support the $3.5 trillion reconciliation measure. A tentative schedule of committee mark-ups, including those in the House Ways and Means and Energy and Commerce Committees, in advance of the September 15 deadline has been released and could be the first occasion for stakeholders to see key details of legislative proposals. Also this month, government funding will expire on September 30 and Congress may take action to raise the debt ceiling—two other key items that may play into the ongoing negotiations for the Biden spending plan.

DEADLINE TO REMOVE ACO PARTICIPANTS AND/OR SNF AFFILIATES
Tomorrow, September 10 at 12:00 pm (noon) ET, is the deadline for ACOs to respond to the CMS Phase 1 RFI-2. This is the last opportunity for ACOs to withdraw or delete ACO participants and/or SNF affiliates. As a reminder for those ACOs who selected the option to hold on finalizing their repayment mechanism arrangement until further notice from CMS, pending issuance of the Calendar Year (CY) 2022 MPFS Final Rule—this is also the deadline to submit draft repayment mechanism documentation to CMS for review. ACOs that selected this option may have a limited opportunity to resolve any deficiencies and have the repayment mechanism approved in time for the start of Performance Year (PY) 2022, so CMS strongly recommends submitting draft repayment mechanism documentation for review. For more information, a CMS application toolkit with helpful guidance and resources. Additional information about the application timeline is available . As a reminder, application dates are subject to change.

HONORING THERESA KNOWLES, QUALITY COMMITTEE MEMBER
On August 26, 2021, Theresa Knowles, Penobscot Community Health Care’s (PCHC’s) Chief Quality Officer for many years and a four-year member of NAACOS’s Quality Committee, passed away from metastatic esophageal cancer just 44 days after being diagnosed. We are so thankful for her service, which included participating on many workgroups, speaking at our conferences and on our webinars. In her 45 years, Theresa did so much good – she was a fierce advocate for the underserved. Theresa leaves behind a husband and four boys. For more information about Theresa’s life, please visit her gofundme page, which has a beautiful obituary.

CMS RELEASES PY 2022 FINANCIAL PAPERS FOR THE GPDC MODEL
On September 3, the Center for Medicare and Medicaid Innovation (Innovation Center) released the GPDC financial papers for Performance Year 2022, and NAACOS created this resource to provide members with an overview of key changes. As expected, the papers include mostly minor changes to the current financial policies. However, as advocated for by NAACOS, the Innovation Center revised its policy of excluding voluntarily aligned beneficiaries from the +/- 3 percent Direct Contracting Entity (DCE)-level cap on risk adjustment. Under the new policy, voluntarily aligned beneficiaries that are newly aligned will be excluded from the cap, but voluntarily aligned beneficiaries that are continuously aligned in the following model performance year will be included. NAACOS anticipates that additional significant revisions to GPDC may be implemented for PY 2023. NAACOS continues to advocate for important revisions, including changes to the benchmarking methodology to create a level playing field for organizations experienced in fee-for-service shared savings initiatives and those that are new to these programs. NAACOS recently sent a letter to CMS detailing our Direct Contracting recommendations, which is part of our ongoing advocacy related to the model. We also continue to monitor the impact of the COVID-19 pandemic and its implications on use of historical expenditures and risk scores in benchmark calculations.

NEXT DIRECT CONTRACTING LEARNING DISCUSSION SET FOR SEPTEMBER 15
NAACOS and fellow DCEs will gather for our next Direct Contracting Learning Discussion on September 15. The event is for 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: 482188). Advance registration is not required, and the meeting will be recorded and posted on our website for those unable to attend it live. We plan to have experts on to discuss compliance but should have time to discuss several other topics. If you have issues you’d like to raise, please share them with [email protected].


DEEP DIVE OF 2020 MSSP RESULTS
NAACOS is still beaming over MSSP’s positive 2020 performance results. As announced by CMS last month, ACOs collectively produced $4.1 billion in gross savings and $1.9 billion after accounting for shared savings payments. NAACOS has published a more thorough analysis of results in this document. Among the additional findings:
  • Just six MSSP ACOs would have paid shared losses if CMS had not waived doing so, citing the COVID-19 Public Health Emergency.
  • MSSP ACOs generated an average savings of $390 per patient compared to their benchmarks, which is a major improvement over the $262 per patient generated in 2019, the previous annual high.
  • The number of ACOs saving the Medicare Trust Fund money has increased every year since 2015, when roughly half of ACOs saved Medicare money.
  • 97 percent of ACOs who started in 2012, 2013, or 2014 generated savings for Medicare in 2020 and none would have owed shared losses. Comparatively, 76 percent of ACOs who started in 2018, 2019, or 2020 generated savings for Medicare in 2020 and four would have owed shared losses.
NAACOS will update this document when results from the Next Generation ACO Model are published. We continue to encourage ACOs to share these results with internal and external audiences, including the press. We have developed a Media Kit to get you started. It’s important to share the results of your hard work and demonstrate the benefits of care coordination and accountable care. Please send your published releases to [email protected], and we’ll publish them on our NAACOS Member News page.

UPDATE MSSP ACO PUBLIC REPORTING TEMPLATE BY SEPTEMBER 24
As is required every year for those in MSSP, ACOs must publicly report organizational information along with financial and quality performance results on a designated webpage. ACOs that participated in MSSP in 2020 have received their individual results, which are now available through this CMS public use file, and these ACOs must also update their public reporting pages with their 2020 results by September 24, 2021. ACOs should refer to the updated Public Reporting Template, posted to the ACO Management System (ACO-MS) on August 25, 2021. It is available in the Program Resources section of the Knowledge Library tab in ACO-MS and includes instructions on how to populate the template and the locations of some of ACO-specific information.

NAACOS also encourages ACOs to tout their work and savings in their local communities. To help ACOs spread news about their positive performance results, we have created a Media Kit for ACOs including a press release template on savings, a tip sheet on sharing your news, and one-page background document on ACOs. As a reminder, ACOs do not need to submit their press releases to CMS for review and approval. We encourage you to share news about your 2020 savings and hope these resources will help you to do so.

NEW APP QUALITY RESOURCES AVAILABLE FOR ACOS
CMS recently provided several new resources aimed at APMs and ACOs on the APM Performance Pathway (APP). The APP is used to evaluate ACO quality for both MSSP and the Merit-Based Incentive Payment System (MIPS). The materials include fact sheets, reporting scenarios, scoring guides and others and are available on the Quality Payment Program Resource Center. The ‘2021 APP Data Aggregation Reporting Scenario’ resource in particular details an acceptable method for aggregating data for APM Entity level submissions.

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2021 MEDICARE TRUSTEES REPORT
Last week, the Social Security and Medicare Trustees released their annual reports on the long-term financial state of the programs. The Medicare Trustees Report found that the Part A Hospital Insurance Trust Fund will be insolvent by Fiscal Year (FY) 2026, which is unchanged from the projections prior to the COVID-19 pandemic. One important aspect of the report showed that significant cost growth is driven in part by the rising costs of Medicare Advantage (MA) as well as the growth of the program. In 2010, only 25 percent of Medicare beneficiaries were enrolled in MA, whereas today 43 percent are. By the 2030s, this number is expected to grow to over 50 percent. The report recommends adopting a better methodology for adjusting MA plan payments to account for diagnostic coding intensity as a way to control costs. While the trustees make several recommendations to improve the financial future of the Medicare program, none of these recommendations involved leveraging value-based care programs as a solution to cost growth. Learn more in this analysis of the report.

EVALUATION OF VERMONT APM SHOWS POSITIVE RESULTS
The CMS Innovation Center recently published a formal evaluation of the Vermont All-Payer Accountable Care Organization Model, and it shows very promising results. The ACO model showed statistically significant Medicare gross spending reductions at both the ACO and state levels, as well as Medicare net spending reductions at the state level. The evaluation found there were declines in acute-care stays and in 30-day readmissions, among other positive findings. The full evaluation as well as “findings at a glance” are on the CMS website. The Vermont model is a six-year model that launched in 2017. It tests whether a state-wide ACO that includes Medicare, Medicaid, and the state’s largest private insurer can reduce spending while preserving or improving quality.