NAACOS SPRING 2021 CONFERENCE BEGINS APRIL 20 The NAACOS Virtual Spring Conference sessions begin at 11:00 am ET on Tuesday, April 20 with an opening plenary with Liz Fowler, director of the Center for Medicare and Medicaid Innovation (CMMI), and a roundtable of discussants from NAACOS’ board. On that opening Tuesday, we will also have a session on Value-Based Contracts: Building Trust Between Payers and Providers and a second plenary with Mark McClellan discussing Value-Base Care’s Future in a Post COVID world. We have a brand-new look and feel to our streaming site this year and we hope that you will all be able to join us. Make sure you register before April 14 so that you receive all of the participant information in a timely manner!
SUBMIT QUESTIONS FOR CMS TOWN HALL SESSION AT NAACOS CONFERENCE NAACOS is busy preparing for a jam-packed spring conference! Our Town Hall with 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 us your questions by emailing advocacy@naacos.com with the subject “Town Hall.”
PRESIDENT BIDEN RELEASES NEXT SPENDING PROPOSAL On March 31st President Biden released his American Jobs Plan, a nearly $2.3 trillion proposal that includes $400B to expand Medicare home and community-based care, $100B for broadband, $18B for Veterans Affairs hospitals, and other measures. The plan would be paid for by significant tax increases on corporations over the next 15 years. House and Senate Democrats are now advancing the proposal, with Speaker Nancy Pelosi setting a goal of passage by the July 4 Congressional recess. Also shaping the legislative landscape, on April 5 Senate Majority Leader Chuck Schumer announced that the Senate Parliamentarian had determined that additional legislative measures could pass via the reconciliation process, opening the door for additional health care measures to move this year. Proposals including lowering the Medicare age and drug pricing reforms may be on the docket in additional reconciliation bills, and it is anticipated that the White House could announce further health care priorities the week of April 12.
CMS EXTENDS ENFORCEMENT DISCRETION ON BENEFICIARY NOTIFICATIONS CMS announced in ACO Spotlight newsletter, Issue 6 that it will continue to exercise enforcement discretion around beneficiary notifications. As it did in 2020, the agency will only require ACOs to send letters by the end of the performance year. Normally, CMS requires ACOs to send a standard written notification either prior to or at their first primary care visit of the performance year. More information is included in the recently updated COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing document.
NAACOS CONTINUES TO EXPRESS CONCERNS TO CMS ABOUT MANDATORY ECQMS NAACOS has held numerous meetings this year with CMS, as well as a recent meeting with the Office of the National Coordinator for Health Information Technology (ONC), to share ACO feedback and express concerns about aspects of the Medicare Shared Savings Program (MSSP) quality overhaul. Thanks to helpful ACO input from our recent quality surveys, we have emphasized areas of concern and impediments to shifting to mandatory quality reporting via electronic clinical quality measures (eCQMs) and Merit-based Incentive Payment System clinical quality measures (MIPS CQMs). We detailed our feedback in this document as well as our recommendation to delay implementation of mandatory eCQM and MIPS CQM reporting until a number of critical issues are resolved.
DIRECT CONTRACTING MODEL’S FIRST PERFORMANCE PERIOD BEGINS The initial performance period of the Direct Contracting Model kicked off on April 1. NAACOS welcomes those participating in the next leading accountable care model from CMMI. We expect CMS to announce participants soon at which time Direct Contracting Entities’ embargo on announcements regarding their involvement will be lifted. A slew of resources from NAACOS and CMS are posted on our website, and our Direct Contracting listserv remains a great way to stay in touch with others interested in the model.
CMS UPDATES COVID-19 HOSPITALIZATION, COSTS DATA FOR MEDICARE Traditional Medicare beneficiaries hospitalized with COVID-19 cost an average of $22,995 per stay. Of the nearly 700,000 COVID-19 hospitalizations across Medicare, 54 percent were a week or less. CMS revealed these numbers in an updated snapshot of COVID-19’s impact on Medicare. To date, there have been more than 2.7 million cases among Medicare beneficiaries. The updated snapshot covers the period from January 1 to December 26, 2020. It is based on Medicare Fee-for-Service claims and Medicare Advantage encounter data CMS received by January 22, 2021.
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MACRA ALERT: WILL YOUR ACO QUALIFY FOR THE 5% AAPM BONUS IN 2022? Nearly 40 percent of ACOs will participate in a qualifying Advanced Alternative Payment Model (Advanced APM) in 2022—allowing their physicians and other clinicians to be eligible to earn a 5 percent bonus if the ACO meets Qualifying APM Participant (QP) thresholds. NAACOS successfully lobbied Congress to freeze the QP thresholds at 35 percent (patient count) and 50 percent (payment) for Performance Years (PY) 2021 and 2022. But, one in five of Advanced APM ACOs could still fail to meet the QP thresholds. If your ACO is in an Advanced APM track or thinking of joining one in 2022, the Institute for Accountable Care can help you plan by estimating your ACO’s 2022 QP score—and importantly—providing estimates for each of your ACO’s physician groups/participant TINs. We can also model the impact of adding or removing specific physician groups/participant TINs on your ACO’s QP score. These services are provided for a fee. Get more information or contact us.
NAACOS RESPONDS TO DELAY OF THE ACO OPTION OF THE CHART MODEL CMMI recently announced it would delay the Request for Applications for the ACO Transformation Track of the Community Health Access and Rural Transformation (CHART) Model from Spring 2021 to Spring 2022. While NAACOS is disappointed given the robust interest our members have expressed in CHART, we issued a statement expressing our desire to see a CHART-like option to help foster the growth of new ACOs in underserved communities. This could be done by a new ACO loan program for rural and small providers. We previously called upon CMS to expand CHART. The recent delay is a short-term setback but provides an opportunity to work with the new administration to grow ACO participation.
MEDPAC VOTES FOR FEWER MODELS FROM CMMI The Medicare Payment Advisory Commission (MedPAC), which advises Congress on payment issues in Medicare, unanimously approved a recommendation that calls on CMMI to test fewer models. The recommendation will be included in a chapter of the June report to Congress. The commission is concerned that model overlap both creates competing priorities for clinicians and creates difficulty in evaluating models. NAACOS has long called on CMS to adapt a center-wide overlap policy, which it has yet to do. MedPAC is expected to discuss the issue of harmonizing various models so they work better together starting later this year. Slides from the meeting are available.
2021 MSSP ADJUSTED HISTORICAL BENCHMARK REPORTS AVAILABLE CMS recently released the PY 2021 Adjusted Historical Benchmark Report packages to ACOs through the ACO-MS Data Hub. All MSSP ACOs should have received a package for PY 2021 as a result of changes in the beneficiary assignment methodology, summarized in this NAACOS resource.
The PY 2021 Adjusted Historical Benchmark Report is based on the ACO’s PY 2021 Participant List and the ACO’s PY 2021 Assignment Methodology. The package includes a number of items, such as the Adjusted Historical Benchmark Report, Annual Assignment List Report, Annual Assignment Summary Report, Annual Aggregate Expenditure/Utilization Report, Annual Beneficiary Expenditure Utilization Report, and the Annual Non-Claims Based Payment File.
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CMMI PUBLISHES UPDATED FINANCIAL PAPERS FOR DIRECT CONTRACTING CMMI recently updated the financial papers for Direct Contracting. While the policies set forth in the papers are also in the model’s Participation Agreement, the papers offer additional context and examples. The updates to the financial papers are primarily non-substantive and align language and terminology with the Participation Agreement for consistency. There are, however, two substantive changes:
How CMMI handles insufficient claims history. If the Direct Contracting Entity (DCE) does not have sufficient claims history to calculate the historical baseline expenditure for any of the three base years, that base year will not be used in the calculation of the final historical baseline. If the DCE has sufficient claims history for two of the three base years, CMS will average the historical baseline expenditures for base years with the more recent base year weighted two-thirds and the less recent base year weighted one-third. If the DCE has sufficient claims history for one of the three base years, CMS will use only that base year to calculate the historical baseline.
An update to the risk adjustment policy. CMS will apply retrospective trends to the benchmarks throughout the year. Under the previous policy, the retrospective trend adjustment would only be made at the end of the year. These mid-year retrospective adjustments are essentially placeholder adjustments but provide more transparency and predictability in what DCEs will see in final reconciliation.
CATCH THE DIRECT CONTRACTING 101 WEBINAR ON-DEMAND If you missed our refresher webinar on Direct Contracting this week, you can still catch it on-demand. This hour-long webinar reviews the basic structure of the Direct Contracting Model. While NAACOS has held similar webinars in the past, this one includes new details recently released by CMS such as those from the Performance Agreements for 2021. While we understand application details are still lacking, this “101” webinar will serve as a primer for more in-depth discussions set to take place during our Spring Conference later this month.
NEXT GEN MODEL COVID-19 ADJUSTMENTS FOR PY 2021 (DA) As CMMI continues to assess the effects of COVID-19 on Next Gen ACOs, it incorporated initial adjustments to the model it its Extension Year (PY6, 2021) Amendment, including:
Starting the performance year with a prospective national trend. However, if there is a significant difference between the prospective trend and the observed growth rate, CMS will retroactively update the prospective trend with this observed growth rate (i.e., based on actual trend in 2020).
Removing expenditures for a COVID-19 episode of care from ACOs’ performance year expenditures for purposes of financial reconciliation. CMS will identify an episode of care for treatment of COVID-19 based on the criteria specified in 42 C.F.R. § 425.611(b)(1).
ACOs will not be responsible for shared losses that may be incurred in the months within the Public Health Emergency (PHE). The PHE is currently scheduled to expire on April 21, 2021, but President Biden has stated that he intends to extend the PHE for the duration of 2021.
Retroactively modifying the Projected Coding Factor for each Base Year based on the observed change in average risk score between that Base Year and 2021.
Using the Direct Contracting measures for Next Gen ACOs participating in the PY6 (2021):
All-Cause Unplanned Admissions for Patients with Multiple Chronic Conditions (UAMCC) (claims reported)
Days at Home for Patients with Complex, Chronic Conditions (DAH)
Consumer Assessment of Healthcare Providers and Systems (CAHPS) Survey (survey conducted by vendor)
The CAHPS measure is weighted 50 percent of the ACO quality score. The other 50 percent will be based on performance in the other three measures. Because Days at Home is a new measure for 2021, the measure is pay-for-reporting.
ADVANCED PAYMENT RECOUPMENT INFORMATION RELEASED CMS has released information on how to begin repaying accelerated and advanced payments provided during the COVID-19 PHE. Repayment begins one year after the advanced payments were first made. After being granted some time to repay these loans, Medicare Administrative Contractors will start to issue demand letters for full repayment with interest accruing at a rate of 4 percent. CMS will show recoupments on the remittance advices issued for claims processed after the one-year anniversary of issuing the first payment. More information on the advanced payments and recoupments are available on CMS’s website.
REGISTER BY JUNE 30 FOR CMS WEB INTERFACE AND CAHPS FOR MIPS SURVEY REPORTING FOR 2021 The 2021 deadline for APM Entities to register for the CMS Web Interface and/or administer the CAHPS for MIPS Survey is 8:00 pm ET, June 30, 2021. Additional information can be found at How to register for CMS Web Interface and the CAHPS for MIPS Survey. Individuals who have the security official role for their ACO will need to sign into QPP, select the Manage Access page, and click “Edit Registration.”
It’s important to note that MSSP ACOs will be automatically registered for the CMS Web Interface and CAHPS for MIPS Survey since each is required to meet the reporting requirements for the quality performance category using the APM Performance Pathway (APP). Even though these ACOs are automatically registered for the CMS Web Interface, ACOs may choose to report quality data for PY 2021 using the MIPS Clinical Quality Measures or eCQMs. The 2021 APM Performance Pathway Quick Start Guide and the 2021 APM Performance Pathway (APP) for MIPS APM Participant Fact Sheet provide more details on what reporting options are available. In addition, Next Generation ACO participants will be automatically registered to report the CAHPS for ACOs Survey.
