NAACOS Newsletter for Members and Partners September 23, 2021

Table of Contents
Still Time to Register for NAACOS Fall 2021 Conference
Submit Your Questions for the Upcoming CMS Town Hall
NAACOS Invites ACOs to Participate in Education Focus Groups
Leading Health Care Associations Urge HHS to Prioritize ACOs and Value
Deadlines Loom in Congress
Upcoming Deadline for Voluntary Alignment
NAACOS Urges Including eCQM Reporting Capabilities in EHR Ratings
Recording of DC Learning Discussion, Other Resources Now Available
HHS Drug Pricing Plan Includes Value-Based Care
CMS to Host APP Webinar September 27
ACO Public Reporting Due September 24
NAACOS Submits Comments to Congressional SDOH RFI
CMS Releases CJR Model PY 4 Evaluation Report
Insights from the Alliance for Health Policy Health Equity Summit

STILL TIME TO REGISTER FOR NAACOS FALL 2021 CONFERENCE
Registration for both the in-person and virtual options for the Fall 2021 Conference are still open, and you can register up until the conference itself, both onsite and virtually! Individuals unable to attend the conference in person can participate in the live webcast, which includes all breakout sessions and plenaries, as well as sponsored sessions. All participants will receive six months of access to the session recordings so you don’t miss any!

There is still time to add a pre-conference workshop to your in-person registration. Our two in-person-only pre-conference workshops will take place on Wednesday, September 29 from 1:00–5:00 pm ET. The topics are “Improving Care for Duals in Your ACO” and “Succeeding with MA Contracts.” These workshops require separate registration and are not offered virtually.

SUBMIT QUESTIONS FOR CMS TOWN HALL AT NAACOS CONFERENCE
The fall conference’s town hall featuring CMS leaders is a great opportunity for ACOs to ask these experts questions on a range of topics affecting ACOs. In addition to encouraging live audience questions during the session, we are soliciting questions we can submit to CMS in advance. Please send your questions by Monday, September 27, by emailing [email protected] with the subject “Town Hall.”

NAACOS INVITES ACOS TO PARTICIPATE IN EDUCATION NEEDS FOCUS GROUP
NAACOS new Vice President of Education, Melody Danko-Holsomback, would like to invite you to participate in a focus group of your choice in four areas of interest: executive leadership, operations, finance, and information technology. The focus groups will occur during the upcoming NAACOS conference for those on-site or virtually within the weeks following the conference for those not attending. The aim of the initial groups is to better understand interest in the development of co-operative sessions to discuss, enhance, and create new educational tools to support each of these areas as ACOs maneuver through the value-based landscape. In addition, the groups will offer excellent networking opportunities. Initial considerations for session scheduling include in-person collaborative breakout sessions at conferences or boot camps with virtual meetings throughout the year. But, who better to provide feedback on the design and setting of these collaboratives than our ACO members?

If you would like to attend one of our upcoming in-person or virtual focus groups to provide your feedback, please complete the following survey, and we will be in touch with more details in the near future: NAACOS-Co-op-Interest-Survey.

Welcome New Business Partners
CareVention HealthCare
CareVention HealthCare offers industry-proven solutions that enhance humanistic, clinical and economic outcomes for organizations and their participants. Our comprehensive services and integrated technology solutions assure your organization’s participant health and safety, optimized financial management, and regulatory compliance.
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OPN Healthcare Inc
With our geographically agnostic delivery models, OPN champions meeting clients on the risk continuum to help improve patient satisfaction, health outcomes, and quality of care with sustainable clinical and financial success.
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Dina
Dina powers the future of home-based care. We are an AI-powered care-at-home platform and network that can activate and coordinate multiple home-based service providers, engage patients directly, and unlock timely home-based insights that increase healthy days at home.
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LEADING HEALTH CARE ASSOCIATIONS URGE HHS TO PRIORITIZE ACOS AND VALUE
NAACOS and 16 other national healthcare associations recently sent a letter to Department of Health and Human Services (HHS) Secretary Xavier Becerra urging HHS to focus on advancing health equity and value in Medicare through alternative payment models (APMs). The letter notes that the MSSP, Medicare’s largest and most successful APM, and models from the Center for Medicare and Medicaid Innovation offer tremendous opportunity and should be supported by HHS and CMS. The letter emphasizes that through accountability for costs and quality, providers in APMs are incented to focus on wellness and care of the whole person proactively and better managing care for populations. The group makes recommendations such as to utilize the MSSP as an innovation platform, to support ACOs through program improvements and policy changes, and to address APM overlap to prevent models from undercutting one another. The letter also requests greater technical support to APM participants to reduce burden associated with model participation and to modify policies to ensure incentives for APM adoption can be reasonably met. This letter is part of NAACOS’ ongoing advocacy and other recent letters to both the administration and Congress are available.

DEADLINES LOOM IN CONGRESS
House Democrats are struggling with the challenges of a tight legislative calendar and fractures in their caucus, making their September work period a bumpy ride. The most significant hurdle at the moment is how to address the debt ceiling and to pass the short-term government spending bill before funding expires at the end of the month. Currently, House Democrats plan to combine the stopgap funding bill with the suspension of the debt limit in an effort to avoid a government shutdown and defaulting on the national debt. Senate Minority Leader Mitch McConnell (R-KY) is warning that Republicans will not support legislation that raises the debt limit, but Democrats have been resistant to pass the debt limit in the reconciliation bill. The stopgap funding bill would last through December 3, 2021, and the debt ceiling would be suspended through December 2022.

House leadership also announced that they plan to follow through with the September 27 vote on the infrastructure bill, but differences between progressive and moderate Democrats on the $3.5 trillion “Build Back Better Act” may push the reconciliation bill into late fall or possibly December. Last week, the House committees managed to meet their self-imposed deadline and advance their portions of the reconciliation texts. House Ways and Means Committee voted to pass the Democrats’ drug pricing proposal in a 24–19 vote, but moderate Democrats on the Energy and Commerce Committee rejected (29–29) a similar proposal that would allow Medicare to negotiate drug prices. Three Democrats, Reps. Scott Peters (D-CA), Kurt Schrader (D-OR), and Kathleen Rice (D-NY) joined all Republicans in voting against the subtitle. It is still unclear if the proposal will make it into the conference version of the bill. NAACOS continues to press Congress to include the Value in Health Care Act (H.R. 4587) in the broader package and urges ACOs to visit our Take Action page to send a letter to lawmakers urging their support for the Value Act.

UPCOMING DEADLINE FOR VOLUNTARY ALIGNMENT
While the vast majority of beneficiaries are assigned to ACOs based on claims, there is increasing emphasis on voluntary beneficiary alignment. Medicare beneficiaries are prospectively assigned to an ACO if the primary clinician to which they voluntarily align is an ACO clinician. The deadline for beneficiaries to select their primary clinician on Medicare.gov and be included in an ACO’s Performance Year (PY) 2022 prospective assignment list is September 30, 2021. While Medicare beneficiaries can continue to select their primary clinicians after that deadline, those selections will be used for prospective assignment to an ACO for PY 2023. ACOs should be aware of the upcoming deadline and encourage beneficiaries to designate their primary clinician. NAACOS continues to advocate for CMS to provide more flexibility and the means by which beneficiaries can make this designation.

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NAACOS URGES INCLUDING ECQM REPORTING CAPABILITIES IN EHR RATINGS
In response to a new Consumer Reports-style electronic health record (EHR) ratings system, NAACOS is encouraging federal health information technology (IT) officials to include quality reporting capabilities, such as the ability to aggregate eCQM data across EHR systems, as a characteristic for which EHRs are judged. NAACOS has seen that EHRs are unable to meet new quality reporting requirements from CMS. That has made reporting across ACO participants extremely difficult. According to a NAACOS survey of ACOs from earlier this year, nearly half of ACOs’ participating practices use 11 or more EHRs, and the biggest barrier cited for movement to eCQM reporting was the lack of EHR standardization. NAACOS believes including eCQM reporting in the new EHR Reporting Program being developed by the Office of the National Coordinator for Health Information Technology (ONC) would help address the issue.

RECORDING OF DC LEARNING DISCUSSION, OTHER RESOURCES NOW AVAILABLE
For those unable to at attend the September 15 Direct Contracting Learning Discussion, the recording is now available. This month, compliance and recently announced changes to the model were discussed. Those changes include financial updates to take effect next year, which are summarized in this new NAACOS resource. All of these resources and more are available on the stand-alone NAACOS Direct Contracting page.

HHS DRUG PRICING PLAN INCLUDES VALUE-BASED CARE
The Biden administration recently released a plan to lower the high cost of prescription drugs, and it names several ways the CMS Innovation Center can get involved. The report says the Innovation Center could consider small-scale mandatory models that link payment for prescription drugs and biologics to factors such as improved patient outcomes, reductions in health disparities, patient affordability, and lower overall costs. The Innovation Center could also consider bundled payments for high-price drugs and ways to better share savings with providers for the use of biosimilars, generics, or other high-value products. The full report, which is non-binding and whose recommendations must still be acted upon, and press release are available.
Central Valley Community Partners LLC
Modesto, CA
Welcome New ACO Members
Crystal Run Health
Middletown, NY
Queen’s MSSP ACO
Honolulu, HI
Welcome New DCE Members
Central Valley Community Partners LLC
Modesto, CA
 
CMS TO HOST APP WEBINAR SEPTEMBER 27
CMS is hosting a webinar on September 27 from 1:30–3:00 pm ET to provide an overview of APM Performance Pathway (APP) criteria. During the webinar, CMS will review APP requirements for ACOs as well as those subject to the APP through the Merit-Based Incentive Payment System (MIPS). Registration is open now. As a reminder, the APP quality scoring approach is effective in 2021 for all MSSP ACOs. For more information on the APP, visit the CMS website or access the CMS APP toolkit.

ACO PUBLIC REPORTING DUE SEPTEMBER 24
MSSP ACOs are required to publicly report ACO organizational information as well as quality and financial performance results. ACOs must update their public reporting webpage with unembargoed PY 2020 Financial Reconciliation and Quality Performance information by the September 24 deadline. CMS provides ACOs with a Public Reporting Template, available in the ACO Management System (ACO-MS) in the Program Resources section of the Knowledge Library.

NAACOS SUBMITS COMMENTS TO CONGRESSIONAL SDOH RFI
Earlier this week, NAACOS submitted comments in response to a Request for Information (RFI) issued by the Congressional SDOH Caucus. This RFI requested feedback on challenges and opportunities in addressing Social Determinants of Health (SDOH). In comments, NAACOS highlighted the great work many ACOs are already doing to address SDOH and made several recommendations for supporting and improving the ACO program to develop and continue SDOH initiatives. Some of these recommendations include increased flexibilities for MSSP ACOs to provide supplemental benefits that address social needs, upfront funding to develop partnerships with community-based organizations (CBOs) and addressing data and interoperability challenges. Supporting and passing the Value in Health Care Act (H.R. 4587) was highlighted as one immediate opportunity for Congress to support ACOs through positive policy changes and improve their ability to screen for, track, target, and address SDOH in their patient populations. Read the full letter.


CMS RELEASES CJR MODEL PY 4 EVALUATION REPORT
CMS recently released its PY 4 evaluation report for the Comprehensive Care for Joint Replacement (CJR) Model. The evaluation found that the 395 mandatory CJR hospitals (in the 34 mandatory metropolitan statistical areas) achieved a statistically significant reduction in average episode payments due primarily to reductions in institutional post-acute care (PAC) use. Despite the reduction in episode payments, the evaluation could not determine the amount of savings to Medicare—if any—because there is a wide range around the estimated savings (ranging from possible losses of $15.3 million to savings of $167.2 million). The report, however, estimates savings of $76 million, or $494 per episode. The report is also limited in that the analyses did not include CJR hospitals located in mandatory MSAs that were designated as low-volume or rural.

INSIGHTS FROM THE ALLIANCE FOR HEALTH POLICY HEALTH EQUITY SUMMIT
Last week, the Alliance for Health Policy hosted a Health Equity Summit during which speakers explored current and historical factors, policies, and practices that perpetuate inequities and discussed tangible policy options to advance health equity. In a fireside chat with CMS Administrator Chiquita Brooks-LaSure, she discussed the importance of value-based care as a tool to improve quality and health equity, as well as to achieve responsible, sustainable stewardship of our healthcare resources. Brooks-LaSure also highlighted the importance of collaborating across stakeholder groups and leveraging lessons learned from state efforts. The session ended with the final remark that every individual working on health equity has an incredible role and opportunity to advance these goals and that if we come together, we will be able to achieve them. Other notable sessions included Measuring for an Equitable Future and the Cost of Health Inequity: Dollars and Sense. A full list of resources for each presentation is available.