NAACOS Newsletter for Members and Partners April 07, 2022
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| NAACOS
CELEBRATES 10-YEAR ANNIVERSARY OF THE MSSP Last week, NAACOS launched a communications campaign to spotlight the 10-year anniversary of the Medicare Shared Savings Program (MSSP), which first began on April 1, 2012. To celebrate this important milestone, NAACOS created a communications toolkit to help others spread awareness and support for Medicare’s largest value-based care program. NAACOS also issued a press release to highlight the significance of MSSP’s 10th birthday and the lessons learned through the past decade of accountable care. Throughout the month of April, NAACOS will be sharing program highlights and ACO success stories on social media with the tag #HappyBirthdayMSSP. You can follow the hashtag and create your own posts to educate others about the value of ACOs!  NAACOS ACTION FUND PRIOR APPROVAL FORMS AVAILABLE ONLINE NAACOS established the NAACOS Action Fund, a political action committee, to support congressional candidates who understand the interests of NAACOS members and value-based care providers. To comply with federal election law, NAACOS members must provide the NAACOS Action Fund with written prior approval before any solicitation may be directed to eligible ACO or company executive and senior administrative personnel. If you are your organization’s primary contact with NAACOS and you have not already done so, we encourage you to electronically sign the NAACOS Action Fund Prior Approval Form. The web-based form includes frequently asked questions and instructions. NAACOS staff will also be at the Spring 2022 Conference in Baltimore to answer questions and accept signed forms. CONGRESS BUSY WITH HEALTH HEARINGS This week Capitol Hill turned to healthcare policy making, including a Senate committee hearing with HHS Secretary Xavier Becerra to review the White House’s Fiscal Year (FY) 2023 health-related budget requests and a House committee hearing on mental health programs. Congressional leaders also introduced a COVID relief package for small businesses, drawing from program integrity initiatives and reserve funds, which could move in the near term. While there had been some movement in the last several weeks on advancing a slimmed-down reconciliation package, which would include provisions on drug pricing, discussions there have temporarily taken a back seat to the more pressing issues of COVID relief, the confirmation of a new Supreme Court Justice, and concern regarding the ongoing conflict in Ukraine. SUMMER BOOTCAMP: IT’S ALL ABOUT THE DATA! Utilizing data to drive performance is one of the key factors to success in value-based care. NAACOS Summer 2022 Boot Camp will take a closer look into how ACOs can utilize their resources to fill data needs and to drive positive performance outcomes. Boot camp faculty will:
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| WHITE
HOUSE RELEASES PRESIDENT’S BUDGET REQUEST On March 28, the White House released President Biden’s FY 2023 budget request. The HHS Budget in Brief is available. The detailed CMS budget justification to Congress is available. While presidential budgets are non-binding and do not carry the force of law, the request does provide an in-depth glimpse of the Biden administration’s top spending and policy priorities for the upcoming federal fiscal year. HHS proposes $127.3 billion in discretionary funding and $1.4 trillion in mandatory and discretionary outlays for CMS, a net increase of $53 billion. The budget requests an extra $19 million for Health Care Quality Initiatives, including funding for ACO program analysis and contracts. The request also includes an additional $22 million for CMS IT systems, including funds for the new cloud based ACO Management System. Additionally, the budget request outlines several policy priorities that should be of interest to ACOs, including:
PY 2022 QUALITY SPECIFICATIONS AVAILABLE With Performance Year (PY) 2021 quality reporting process now complete, make sure your ACO is now referring to the new PY 2022 quality measure specifications. CMS released the 2022 quality measure information earlier this year for both Web Interface and Merit-Based Incentive Payment System (MIPS) clinical quality measure information and supporting documents. Electronic clinical quality measure (eCQM) specifications can be accessed via the eCQI Resource Center. NAACOS also has a resource to assist members in understanding how to access eCQM specifications, which are displayed differently than Web Interface and MIPS CQM measures. In addition, the Quality Payment Program (QPP) resource library includes an APM Performance Pathway (APP) toolkit providing an overview of quality requirements for the APP. The NAACOS quality page includes additional resources and information for ACOs on quality requirements. SEND QUESTIONS FOR CMS TOWN HALL AT NAACOS SPRING CONFERENCE In just a few weeks, hundreds of ACOs from across the country will convene in Baltimore for the jam-packed NAACOS Spring 2022 Conference. The CMS Town Hall is among the many educational sessions and events. During the Town Hall, CMS leaders will share insights on where the transition to value is headed and will answer ACO questions on a range of important policy and ACO program aspects. Live audience questions will be answered along with questions submitted in advance. We encourage ACOs to send us questions before April 23 by emailing us at advocacy@naacos.com with the subject line “Town Hall.” There is still time to register for the conference if you haven’t yet!  KEY ACO APPLICATION DEADLINES FOR 2023 For those wishing to begin participation in a Medicare ACO program for a January 1, 2023, start date, some key application deadlines are approaching. ACOs interested in the ACO REACH Model must submit applications via the ACO REACH Application Portal by 11:59 pm ET on April 22, 2022. The application is non-binding. More information can be found in the Request for Applications (RFA) and the Frequently Asked Questions (FAQ) document, which was recently published. As a reminder, current Direct Contracting Entities (DCEs) do not need to submit an application but must meet all of the updated model requirements prior to the January 1, 2023, start date. CMS has also published the application timeline for participation in the MSSP for the 2023 performance year. ACOs must submit a Notice of Intent to Apply (NOIA) through the ACO Management System (ACO-MS) by the specified deadline in order to be eligible to submit a full application. The window to submit a NOIA will be open from June 1–June 7, 2022, at 12:00 pm ET. CMS has provided resources with information on how to submit a NOIA. Following the NOIA window, the Phase 1 application window will be open from June 8–June 29, 2022, at 12:00 pm ET. Additional details on the MSSP application and an application toolkit and Application Types & Timelines are available. As a reminder, these dates are subject to change. NAACOS will continue to follow application deadlines and update our members. CMMI PUBLISHES AUDITING AND COMPLIANCE OUTLINES FOR ACO REACH As part of its evolution from Global and Professional Direct Contracting (GPDC) to ACO REACH, CMS has promised more oversight, vetting and monitoring of participants and their interactions with beneficiaries. CMS attempts to shed more light on that monitoring in a new document that spells out in greater detail what it’ll be watching for and how. More details are needed, but this is a helpful summary of what those in GPDC and ACO REACH can expect. CATCH NAACOS’ LATEST ACO REACH WEBINAR ON-DEMAND If you missed this week’s NAACOS webinar on ACO REACH, slides and recording are available. This week’s webinar shares the perspectives of a current MSSP ACO and DCE on how they’re evaluating the model and the challenges and opportunities they see. We also took a deep dive into the application process, sharing what applicants should be aware of. Get additional resources and information on ACO REACH. If you have questions about ACO REACH, NAACOS staff are available to answer them by emailing us.  CMS FINALIZES 2023 MEDICARE ADVANTAGE POLICIES Medicare Advantage plans stand to receive an 8.5 percent payment increase in 2023 under the final call letter and rate notice published by CMS this week. This is more than the proposed 8 percent bump. Of this, there’s a 3.5 percent annual increase in risk scores. NAACOS commented on the disparity between how CMS treats MA plans and ACOs in terms of benchmarking and risk adjustment. The full regulation and fact sheet are available. CMS sought feedback on how to measure or incentivize MA plans working with providers in value-based care payment arrangements. NAACOS wrote in our comments that CMS should encourage MA plans to work with ACOs. CMS said it would consider comments it received in future rulemaking. CMS also sought feedback on a number of health equity/SDoH-related matters, which we also commented in favor of. All of CMS’s changes to health equity policies, if there are any, will come in next year’s proposed call letter. MSSP PY 2022 BENCHMARK REPORT PACKAGES AVAILABLE CMS recently made available key benchmarking reports for MSSP ACOs, which are available in the ACO Management System (ACO-MS). The PY 2022 reports include preliminary or adjusted historical benchmark reports along with files pertaining to each of the ACO’s three benchmark years. ACOs with agreements that began on January 1 of this year received the preliminary PY 2022 Historical Benchmark Reports, based on data from benchmark years 2019, 2020, and 2021. These ACOs will receive a final historical benchmark report package later this year, after three months of claims run-out from 2021 and all relevant data inputs are available. Adjusted historical benchmark reports were made available to ACOs continuing an ongoing agreement in PY 2022. These reports reflect annual updated to ACO participant lists and/or assignment methodology changes. If there were no ACO participant list or beneficiary assignment methodology changes, the benchmark will not be adjusted, and these ACOs will not receive adjusted historical benchmarks. CMS CONDUCTS CEHRT AUDITS NAACOS understands that CMS has begun sending notices to select MSSP ACOs that it is conducting audits around the use of Certified Electronic Health Record Technology (CEHRT). In MSSP, at least 75 percent of ACOs’ eligible clinicians must use CEHRT. While CMS has pretty broad audit authority, NAACOS is unaware of the agency auditing for CEHRT use in the recent past. NAACOS is trying to stay abreast of these audits and will update members as we learn more. CMS WEBINAR ON BUILDING PARTNERSHIPS WITH CBOS CMS will host a webinar for ACOs on building partnerships with community-based organizations (CBOs) on April 20 from 3:00–4:00 pm ET. This webinar will explore how to build sustainable relationships with CBOs to better serve beneficiaries. Speakers will feature an MSSP ACO as well as a participant in the Accountable Health Communities Model and will discuss how to identify CBO partners that can help support unmet beneficiary needs. Registration details are available. NAACOS has a number of resources to support ACOs working to improve health inequities. |
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| CMS
RELEASES SEVERAL PROPOSED PAYMENT RULES Last week, CMS published three payment rules for inpatient psychiatric, inpatient rehabilitation facilities, and hospice providers. CMS is proposing to apply a permanent 5 percent cap on wage index decreases for all three payment systems. The FY 2023 Inpatient Psychiatric Facility Prospective Payment System proposed rule updates payment rates by 2.7 percent with estimated payments to increase by 1.5 percent after productivity adjustment. It also requests comments on the payment system refinement analysis. The fact sheet and proposed rule are available. The FY 2023 Inpatient Rehabilitation Facility (IRF) Prospective Payment System and Quality Reporting Program proposed rule updates payment rates by 2.8 percent, with estimated overall payments to increase by 2.0 percent after productivity and outlier adjustments. It also expands quality data reporting on all IRF patients, regardless of payer. The fact sheet and proposed rule are available online. The FY 2023 Hospice Wage Index Payment Rate proposed rule updates payment rates by 2.7 percent and provides an update on the development of a patient assessment instrument, titled HOPE, which would contribute to a patient’s plan of care when adopted. The fact sheet and proposed rule are available online. NAACOS SIGNS ON TO PRIMARY CARE RECOMMENDATIONS Last week, NAACOS joined dozens of other organizations in signing on to support the recently-published Concordance Recommendations for Primary Care Payment and Investment as part of the “Better Health – Now” campaign, led by the Primary Care Collaborative (PCC). This effort was prompted by the 2021 National Academies of Sciences, Engineering, and Medicine (NASEM) report, Implementing High-Quality Primary Care, which calls for our health system to pay for primary care teams that are accountable to communities. The first recommendation in the report is to reform how we pay for primary care and invest more in primary care so that every community can achieve better health. The goals of this campaign are to encourage policies that change the way we pay for health care to support robust primary care teams and high-value care and to reduce economic and social barriers to achieving better health. CMS TO DISCUSS HEALTH EQUITY AT UPCOMING QUALITY CONFERENCE Next week, CMS is hosting its virtual 2022 Quality Conference on April 12–13. The CMS Office of Minority Health (OMH) will be leading several sessions focused on health equity. Dr. LaShawn McIver, CMS OMH Director, will speak on the charge to advance health equity by addressing the health disparities that underlie our health system and assessing the equity implications of policy choices and investments. Following this, CMS OMH will be leading three breakout sessions on various topics related to health equity, including data and the social determinants of health (SDOH), rural health equity, and stakeholder engagement and individuals with disabilities. More information is available in the detailed agenda. MEDPAC HOLDS MEETINGS ON APMS AND SDOH The Medicare Payment Advisory Commission (MedPAC) will hold their final spring public meetings on April 7 and April 8. During this week’s meeting, the commission will hold another session Friday morning discussing integrating episode-based and population-based payment models. These sessions are a continuation of the work the commission has been doing for the last year on APMs. MedPAC will be publishing a follow-up chapter on APMs in its June 2022 report that NAACOS will be summarizing for our members. The commission will also hold a session Thursday afternoon to discuss leveraging Medicare polices to address SDOH. The full MedPAC agenda is available. |
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