NAACOS Newsletter for Members and Partners April 21, 2022

Table of Contents
Can’t Travel? Attend Spring Conference Virtually!
COVID-19 PHE Extended into July
More ACO REACH Deadlines Announced
CMS Releases Proposed Payment Rules
Last Chance to Send Questions for CMS Town Hall
Congress Eyes MidTerm Wins
NAACOS Action Fund Prior Approval Forms Online
Data Makes the ACO Go ‘Round!
NAACOS Launches Digital Quality Task Force
CMS Moves to Limit Aduhelm Coverage
NAACOS Enhances Resources Touting ACO Model
CMS Indefinitely Delays Radiation Oncology Model
NAACOS Submits Comments in Response to PTAC RFI
MedPAC Holds Session Discussing APMs
Congress Introduces SDOH Legislation
White House Releases Equity Action Plan Across Federal Agencies
Last Chance to Join the Specialist Learning Lab Kick-Off on April 27
NAACOS Hosting Webinar on MSSP Benchmark Reports

CAN’T TRAVEL? ATTEND SPRING CONFERENCE VIRTUALLY!
ACOs, DCEs, and other models focusing on population health can create a future where quality is better, costs are lower, and patients are engaged. Join us on April 28–29 from the comfort of your home, office, or wherever it may be, and hear from leading value-based care experts and CMS officials sharing timely and essential information for ACOs and other alternative payment models. A detailed agenda is available!

Register Now
Registration is still open for the virtual conference! Individuals unable to attend the conference in person can participate in the live webcast of the conference. The live webcast includes all of the breakout sessions and plenaries as well as the sponsored breakfasts. Live webcast participants also receive six months of access to the recordings of the sessions so that you don’t miss out on any of the sessions! Please note, the live webcast does not include any of the pre-conference workshops.

Still thinking about traveling to Baltimore to attend in-person? Don’t worry! In-person registrations are available.

NAACOS conferences are the only events organized exclusively by ACOs and DCEs. Get more information on conference registration and hotel details.


COVID-19 PHE EXTENDED INTO JULY
Effective April 16, Health and Human Services (HHS) Secretary Xavier Becerra renewed the COVID-19 Public Health Emergency (PHE) for an additional 90 days, as NAACOS had been expecting. With another 90-day extension, the PHE will now last through July 15. A number of Medicare polices are tied to the PHE, including CMS waiving shared losses for MSSP ACOs, removing COVID-19 treatment episodes from PY expenditures, and broad application of telehealth waivers. More information is available on COVID-19. We are continuing to monitor the PHE’s timeline and will alert members of significant happenings.

MORE ACO REACH DEADLINES ANNOUNCED
The CMS Innovation Center recently announced two key upcoming deadlines for the ACO REACH Model. The deadline to add providers will be August 4, and the deadline to drop providers is September 9. Both of these dates coincide with the MSSP. NAACOS understands these are tight turnarounds that put a lot pressure of ACOs, especially since financial information won’t be released until this summer. The agency still hopes to send decisions on 2023 applications by late June. More information is available on the Innovation Center calendar.

CMS RELEASES PROPOSED PAYMENT RULES
On April 18, CMS issued the Fiscal Year (FY) 2023 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospital (LTCH) Prospective Payment System (PPS) Proposed Rule. Comments on the proposed rule are due by June 17. The fact sheet and proposed rule are available. CMS proposes to increase inpatient hospital payments by 3.2 percent in FY 2023. Long-term care hospitals would see an increase of $25 million while Medicare dependent hospitals would see a $0.6 billion decrease in payments unless Congress passes legislation to stop the reductions. CMS is proposing to apply a 5 percent cap on any decrease to a hospital’s wage index from the prior year. CMS is proposing to require hospitals to continue COVID-19 and seasonal influenza reporting after the end of the PHE.

The proposed rule also builds on the Biden administration’s key priorities to better measure health care quality and disparities. Specifically, CMS is seeking comments on how the reporting of social determinants of health (SDOH) diagnosis codes may improve the ability to recognize severity of illness, complexity of service, and/or utilization of resources. The proposed rule also seeks comments on ways to address disparities and advance health care equity. CMS also proposed several changes to Electronic Clinical Quality Measures (eCQMs) and hybrid measures with another request for information to gather comments on continued advancements to digital quality measurement and the use of the Fast Healthcare Interoperability Resources (FHIR) standard for eCQMs.

On March 30, CMS also released the FY 2023 Skilled Nursing Facilities Prospective Payment System (SNF PPS) Proposed Rule that would reduce Medicare nursing home pay by $320 million in FY 2023 to ensure that the program remains budget neutral. Comments on the proposed rule are due by June 10. The fact sheet and proposed rule are available. As with other FY 2023 proposed rules, CMS is proposing a 5 percent cap on wage index decreases. The proposed rule includes a request for information on the implementation of federal staffing minimums, the creation of a staff turnover measure for use in the value-based purchasing program (VBP), and the establishment of a health equity measure as part of the nursing home star ratings system. CMS also proposes the adoption of several new measures into the SNF VBP Program, including measures that assesses the rate of successful discharges to community from a SNF setting.

Welcome New Business Partners
Allymar Health Solutions
Allymar Health Solutions was built to bring value and drive accurate HCC coding via its proprietary end-to-end technology enabled Medicare Advantage platform.
allymarhealth.com
Gallagher Re
A global reinsurance broking and advisory firm across the risk and capital spectrum, revitalizing the industry, redefining innovation, and reimagining what’s possible.
ajg.com/gallagherre/
AristaMD
AristaMD is focused on improving health equity and patient outcomes through more timely access to specialty care.
aristamd.com
Lumeon
Our award-winning orchestration platform enables providers create and automate programmable care journeys, transforming their EHR into an agile care delivery platform to engage patients & care teams beyond the hospital’s four walls.
lumeon.com
Cricket Health
Cricket Health is a value-based provider of kidney care focused on identifying undiagnosed chronic kidney disease and delivering proactive disease management and education.
crickethealth.com
Newtopia
Newtopia is a tech-enabled habit change provider focused on disease prevention and reducing the cost of care.
newtopia.com
FeelBetter US Inc.
FeelBetter enables value-based programs (VBP) to focus on polypharmacy patients that can yield the most significant impact on clinical and financial outcomes.
feelbetter.healthcare
Rimidi, Inc.
Rimidi’s leading clinical management platform empowers healthcare organizations to optimize clinical workflows, enhance patient experiences and achieve quality objectives.
rimidi.com
Fitscript
FITSCRIPT LLC is a digital health and fitness company providing online and in person fitness and coaching to people living with diabetes and chronic conditions around the globe.
glucosezone.com
ThoroughCare
ThoroughCare’s intuitive software, analytics, and mobile applications are designed to support a holistic, continuum of care for healthy patients and thriving practices.
thoroughcare.net
LAST CHANCE TO SEND QUESTIONS FOR CMS TOWN HALL
Next week 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 anticipated 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.”

CONGRESS EYES MIDTERM WINS
Congress is out of Washington, D.C., this week and in a work period in members’ respective states and districts. With a heated election primary season underway and members looking toward the midterm elections in November, the need for wins that can be touted on the campaign trail becomes more urgent. Republicans are favored by pundits and pollsters to win the U.S. House, and GOP offices have begun drafting concrete ideas concerning health access for rural populations and digital health. On the majority side, Democrats see a swiftly closing window to pass drug pricing legislation or lower healthcare costs, creating an appetite to revive reconciliation legislation considered earlier this Congress. At the same time, time sensitive legislation like the medical device and pharmaceutical user fees bills and pending COVID relief are also taking up time on the calendar. During the first week of April, which was the last week that Congress was present in Washington before adjourning, COVID reared its head again, infecting congressional members and staff and perhaps raising the likelihood that COVID relief could pass when Members return to the Capitol next week.

Throughout this year NAACOS will be advocating hard to extend the 5 percent Advanced Alternative Payment Model incentive, among other advocacy priorities. We strongly encourage ACOs to engage in advocacy efforts in a variety of ways, such as by sending a message through our grassroots center and contacting lawmakers while they are at home in their districts.

NAACOS ACTION FUND PRIOR APPROVAL FORMS AVAILABLE ONLINE
The NAACOS Action Fund is a political action committee to support congressional candidates who understand the interests of NAACOS members and value-based care providers. If you are your organization’s primary contact with NAACOS, and you have not already done so, we encourage you to visit our website to review and 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.

DATA MAKES THE ACO GO ‘ROUND!
Everything we do in value-based care contracting revolves around data. NAACOS understands this, and we will take a deep dive into ACO data needs at our upcoming Summer Boot Camp June 16 and 17 in Nashville at the Sonesta Nashville Airport. This boot camp will provide an opportunity to learn from ACOs with demonstrated success in harnessing data to drive positive performance outcomes. Boot camp faculty will present how they use data to drive these processes. We will include breakout sessions that take a deeper look into technical questions around benchmarking, dashboards, claims and coding data.

Some examples include:
  • Creating dashboards to support the needs of leadership, providers, and staff
  • Using claims data for risk calculation
  • Thinking through data resource needs for population health strategy and outcome tracking
  • Understanding how to assess year over year population trends using claims and electronic medical record data
  • Evaluating specialist performance in ACOs
This boot camp is designed for the ACO leadership team, including executive directors, population health staff, as well as data, analytics, and information technology (IT) team members. We will have workshops that speak the language of those responsible for data management and reporting in ACOs. Registration is now open. This summer boot camp will only be offered in person; there is no virtual option. Boot camps are not open to business partners. Space is limited to 100 people from ACOs!


NAACOS LAUNCHES DIGITAL QUALITY TASK FORCE
NAACOS recently announced the launch of its Digital Quality Measurement Task Force (Task Force) aimed at developing recommendations for how to successfully collect and electronically report on ACOs’ quality of care through disparate health IT systems. CMS has made it a goal to fully move to digital quality measurement by 2025. The Task Force will convene ACO leaders and other experts to identify current capabilities and obstacles, helping generate potential solutions and recommendations that will be published in a policy paper later this year. It will then gather stakeholders, including CMS, the Office of the National Coordinator for Health IT (ONC), and health IT vendors, to discuss and react to the policy recommendations. The Task Force is chaired by Katherine Schneider, MD, past NAACOS board chair.

CMS MOVES TO LIMIT ADUHELM COVERAGE
Following NAACOS’s advocacy, CMS will limit coverage of monoclonal antibodies that target amyloid for the treatment of Alzheimer’s disease to patients participating in qualifying clinical trials. NAACOS urged CMS to finalize its proposed National Coverage Determination (NCD), citing concerns that the expected costs of Aduhelm (aducanumab) would outweigh its clinical benefits. NAACOS was supportive of the narrow proposed NCD until more scientific evaluations exist to support the drug’s efficacy. The list price of $28,000 per person for a year of treatment is nearly two-and-one-half times the average ACO’s benchmark.

NAACOS ENHANCES RESOURCES TOUTING THE ACO MODEL
As part of increased efforts to spread awareness and understanding about ACOs and value-based care more broadly, NAACOS has published a new “About ACOs” page as part of the NAACOS website. This public webpage includes a description of ACOs, including what they are and the goals of accountable care, resources on various ACO topics, information on key Medicare ACO programs, and answers to frequently asked questions. NAACOS will continue to update this page with additional resources and educational videos aimed at a general audience that may not be familiar with the jargon of value-based care. These resources are intended to be shared broadly, and NAACOS will use them in conversations with congressional staff, patient advocacy groups, and other key stakeholders. We encourage ACOs to use these to educate patients, their communities, and any other stakeholders who would benefit from understanding the ACO model and the benefits it provides.

CMS INDEFINITELY DELAYS RADIATION ONCOLOGY MODEL
In a Federal Register notice published earlier this month, the CMS Innovation Center is delaying until “a date to be determined through future rulemaking” the start of the Radiation Oncology Model. The mandatory model would test bundled payments for 90-day treatment episodes for certain types of cancers. It has already been twice delayed by Congress. The Innovation Center’s Oncology Care Model is slated to end on June 30 with no alternative yet announced either.

Welcome New ACO Member

Bluestone ACO
Jacksonville, FL

NAACOS SUBMITS COMMENTS IN RESPONSE TO PTAC RFI
Last week, NAACOS submitted comments to the Physician-Focused Payment Model Technical Advisory Committee (PTAC) in response to a request for input (RFI) issued by the committee to solicit feedback from stakeholders on issues related to the design and implementation of population-based total cost of care (TCOC) models. This request is part of a broader effort by PTAC to give committee members information about current perspectives on the role that population-based TCOC models can play in optimizing health care delivery and value-based transformation in the context of alternative payment models (APMs). NAACOS’ comments include information and recommendations on a variety of factors that affect the success of population-based TCOC models such as ACOs. Issue areas included payment structures and financial incentives, care delivery strategies, health equity and clinical quality considerations, and perspectives on provider readiness, participation incentives, and administrative burdens associated with participation in a population-based TCOC model. Given CMS’s goal to have all traditional Medicare beneficiaries in a care relationship with accountability for quality and total cost by 2030, it will be important that TCOC models include an appropriate balance of risk and reward to attract provider participation and sound program fundamentals to ensure success and sustainability.

MEDPAC HOLDS SESSION DISCUSSING APMS
On April 8, the Medicare Payment Advisory Commission (MedPAC) held a meeting to discuss an upcoming chapter in the June report about ideas for streamlining and harmonizing Medicare’s portfolio of APMs. The commission sees ACOs and population-based models as a building block for Medicare’s APMs. Building off the commission’s 2021 recommendations for CMS to implement a more harmonized portfolio of fewer APMs, commissioners favor a smaller number of tracks for ACOs, along with eliminating the periodic “rebasing” of an ACO’s spending benchmark. The commission also favors operating a national episode-based payment model concurrently with ACOs. Under this type of model beneficiaries in an ACO would be concurrently attributed to both models during the episode. NAACOS met with MedPAC staff in March to discuss concerns about how mandatory episodes could negatively impact ACOs. NAACOS will be closely following and summarizing the June report for our members.

CONGRESS INTRODUCES SDOH LEGISLATION
Last week, Senator Cory Booker (D-NJ) and Representative Terri Sewell (D-AL) introduced the John Lewis Equality in Medicare and Medicaid Treatment (EMMT) Act of 2022 that would require the CMS Innovation Center to work with experts to consider health disparities when developing payment models. Under current law, the Innovation Center is only required to consider a model’s ability to lower costs and improve quality. This bicameral legislation would add a requirement for the Innovation Center to also consider models’ potential to reduce health disparities. In addition, it includes requirements for the Innovation Center to consult experts in health disparities and social determinants of health on developing new payment models that focus not only on lowering costs but also advancing health equity and improving access to care, to include those experts during the evaluation of new payment models, and to create a Social Determinants of Health Model that tests payment and delivery innovations to address behavioral health services, dual-eligible beneficiaries, and maternal mortality. Innovation Center Director Liz Fowler has stated the intention “to consider health equity at every stage of our models, from model development to participant recruitment through model evaluation,” and NAACOS has offered several recommendations to the Innovation Center on strategies to advance health equity through ACOs.

WHITE HOUSE RELEASES EQUITY ACTION PLAN ACROSS FEDERAL AGENCIES
Earlier this month, the White House released the first Equity Action Plans across more than 90 federal agencies, as called for in President Biden’s Executive Order on Advancing Racial Equity and Support for Underserve Communities Through the Federal Government. The HHS Equity Action Plan includes six new strategies to advance health equity. These strategies focus on maternal mortality, language access issues in health care, incorporating equity into grants, implementing equity assessments across the department’s policies and programs, investing resources to advance civil rights, and expanding contract opportunities for small, disadvantaged businesses. Other departments’ equity action plans that include health equity elements are the Department of Veterans Affairs, the Department of Agriculture, and the Office of Personnel Management. NAACOS will continue to monitor the administration’s efforts to advance equity and share relevant information with members. To learn more about NAACOS’ ongoing work to support ACOs’ ability to address health equity, visit our health equity page.

LAST CHANCE TO JOIN SPECIALIST LEARNING LAB ON APRIL 27
The in-person kickoff for NAACOS Inaugural Learning Lab will occur in less than a week in Baltimore. If you would like to join us for this in-person brainstorming and project mapping session focused on ACO needs to integrate and engage specialty providers in their networks, SIGN UP NOW to assure you receive the meeting materials. The kickoff will be followed by monthly virtual sessions to continue the conversations and work toward creating ACO resources on specialist integration and engagement.

The NAACOS Learning Lab is designed to provide a deep dive into fundamental strategies in accountable care and to foster exchange among peers with frontline experience. To attend the Learning Lab, ACO members can register at no cost for participation. We are limiting participation to one person per organization for this in-person event. Additional staff may participate in follow up lab activities held virtually in the coming months.

If a representative from your ACO has expertise to present or would like to take a more active role in the lab’s ongoing activities, please reach out to Melody Danko-Holsomback, NAACOS Vice President of Education, mdholsomback@naacos.com. And don’t forget to Register Today to join us in Baltimore.

NAACOS HOSTING A WEBINAR ON MSSP BENCHMARK REPORTS
Join us May 3, 2022, at 2:00 pm ET as NAACOS hosts Mercy ACO and Milliman as they take a first-hand look at the MSSP preliminary benchmark reports. Mike Sarli from Mercy ACO will present on the ACO’s 2022 renewal experiences, as Milliman provides the expertise and support on what these and future reports may mean for your ACO in the coming year. Sign up now to join us for this event!