NAACOS Newsletter for Members and Partners August 11, 2022

Table of Contents

NAACOS ADVOCACY

Join NAACOS to Discuss Direct Contracting and ACO REACH
NAACOS Responds to HHS Primary Care RFI
NAACOS Launches Monthly Government Relations Advocacy Calls

CONGRESSIONAL UPDATES

Senate Passes Inflation Reduction Act
Senate Appropriations Committee Releases FY 2023 Funding Bills
House Considers Telehealth Extension and MA Prior Authorization

ADMINISTRATION UPDATES

ACO REACH Financial Papers Published
CMS Requests Feedback on MA
CMS Publishes Final Payment Rules
CMS Posts 2020 QPP Experience Reports
CMS Highlights Lessons from AHC Model

WHAT WE’RE WATCHING

Report Examines Intersection of Data Sharing and Value-Based Care

EDUCATION OPPORTUNITIES

Can’t Attend Fall Conference In Person? Register for Live Webcast!
MSSP Repayment Mechanism Submission Date Fast Approaching
In-Person Learning Labs Coming on September 7

DATA UPDATE

ACO Quality and Healthcare Disparities
AWV Study

NAACOS ADVOCACY

JOIN NAACOS TO DISCUSS DIRECT CONTRACTING AND ACO REACH
NAACOS monthly Direct Contracting Learning Discussion is a forum for shared learning, and we encourage you to join us and raise questions, share your experiences, and react to issues. The next meeting is August 19 from 12:00 – 1:00 pm ET. We will discuss the recent release of the ACO REACH financial methodology, among other issues. Advance registration is required. Please share any questions or discussion topics in advance by emailing directcontracting@naacos.com.

In addition, you are encouraged to join the ACO REACH Financial Methodology Webinar on August 23; registration is free for NAACOS members and business partners. The deadline for deciding between ACO REACH and MSSP is September 9. The webinar will review the financial methodology and provide an actuarial comparison between MSSP and REACH.

NAACOS RESPONDS TO HHS PRIMARY CARE RFI
Last week, NAACOS submitted feedback in response to a Department of Health and Human Services (HHS) Request for Information (RFI) on strategies to strengthen primary care. The RFI is part of the HHS Initiative to Strengthen Primary Health Care. In comments, NAACOS highlighted the ACO model as a key lever to strengthen primary care and recommended several policies that would enable ACOs to advance primary care innovation and transformation.

NAACOS LAUNCHES MONTHLY GOVERNMENT RELATIONS ADVOCACY CALLS
For the remainder of the year, we are focused on advancing the Value Act and getting Congress to extend the Advanced Alternative Payment Model (APM) incentive payments. To ensure that we are closely aligned with your government relations teams, NAACOS will be holding monthly calls for your in-house or contracted government relations teams. These calls will be an informal forum for sharing updates on congressional outreach and materials that can be used in congressional meetings. The calls are scheduled for 2:00 pm ET on the third Thursday of each month. The next call is scheduled for August 18. Contact Aisha Pittman and Robert Daley to have your organization’s in-house or external government relations team join.

Welcome New Business Partners
1upHealth
At 1upHealth we’re connecting an ecosystem of payers, providers, patients, life sciences and app developers within a trusted interoperability network. Our fully cloud-based and purpose-built platform is built to deliver broad-scale interoperability across a patient-mediated network of over 10,000 clinical endpoints – allowing for greater ease and efficiency to improve patient outcomes, drive population-level analytics and enable medical innovation.
1up.health
Electronic Caregiver Inc.
ECG offers flexible options for health network integration, implementation support and promotes the most robust privacy and security protocols available. ECG’s enterprise platform and services are HIPAA compliant, rigorously tested and certified by an AWS Well Architected Review.
electroniccaregiver.com
Quality Reviews
Quality Reviews, also known as Q Reviews, helps healthcare organizations to increase patient and member engagement throughout their care journey. With a suite of digital solutions, providers and payers can deliver a digital experience with safer, empathetic, and actionable instructions.
q-reviews.com
CONGRESSIONAL UPDATES

SENATE PASSES INFLATION REDUCTION ACT
On August 7, the Senate passed the Inflation Reduction Act (IRA) by a vote of 51 to 50, with Vice President Kamala Harris casting the tie-breaking vote. The bill is expected to be voted on and passed in the House of Representatives on August 12 and then proceed to the White House for President Biden’s signature. In addition to climate, energy, and tax measures, the bill includes several healthcare provisions:
  • Drug Pricing. The bill would create (1) a Medicare drug pricing negotiation program for certain high price pharmaceuticals, (2) rebates for Medicare Part B or D drugs when prices increase faster than inflation, and (3) lower out-of-pocket thresholds and a new manufacturer discount program for certain Medicare Part D drugs.
  • Affordable Care Act (ACA) premium subsidies. The bill would extend federal subsidies for an additional three years through 2025. Of note, this extension is a year longer than originally proposed, placing the issue effectively “off-the-table” until a year after the 2024 Presidential Election.
With consideration of the IRA nearly complete, lawmakers will recess. Upon return to Washington in September, lawmakers will begin laying out priorities that need to be addressed before the end of the year. NAACOS has been working with our stakeholder partners asking Congress to prioritize an extension of the 5 percent Advanced APM bonus.

SENATE APPROPRIATIONS COMMITTEE RELEASES FY 2023 FUNDING BILLS
The Senate Appropriations Committee released a package of Fiscal Year (FY) 2023 funding bills. The package includes funding for HHS, CMS, and $21 billion in emergency supplemental funding for COVID-19. Democratic and Republican leaders in the House and Senate will need to reach a bipartisan agreement in the coming weeks to extend government funding past the end of the fiscal year, which ends on September 30.

HOUSE CONSIDERS TELEHEALTH EXTENSION AND MA PRIOR AUTHORIZATION
On July 27, the House passed legislation to extend Medicare’s COVID-19 telehealth waivers for two additional years until 2024. This includes waivers for originating site requirements, audio-only telehealth, and an expanded list of telehealth practitioners. The bill would also allow for qualified health centers and rural health clinics to be reimbursed for telehealth services. Committee leaders have said Congress needs more time to study and examine current telehealth flexibilities before lawmakers consider a permanent expansion. The bill now moves to the Senate where it’s likely to be amended before further consideration later in the year.

The House Ways and Means Committee recently approved Rep. Suzan DelBene’s (D-WA) bipartisan bill to reform the Medicare Advantage (MA) prior authorization process. Specifically, the bill would require MA plans to adopt electronic prior authorization process, provide real-time decisions for routinely approved items and services, and publish information on approval rates and response time. The bill is now cleared to be considered by the full House of Representatives following the August Recess.


ADMINISTRATION UPDATES

ACO REACH FINANCIAL PAPERS PUBLISHED
The CMS Innovation Center has published financial methodology papers for the ACO REACH Model. The papers are broken out by topic and include an overview, capitation, risk adjustment, the rate book, and settlements. There are few changes beyond the Global and Professional Direct Contracting (GPDC) Model and previously announced changes such as the health equity benchmark adjustment. Join the NAACOS webinar on the differences between REACH and MSSP on August 23 and read our summary of the REACH financial methodology.

CMS REQUESTS FEEDBACK ON MA
CMS released a request for information seeking feedback on aspects of the MA program. The agency seeks input on improving health equity, access to care, affordability, and how MA plans work with ACOs. NAACOS previously provided input on how MA plans work with ACOs in response to the annual MA call letter. If you have feedback for NAACOS on how your ACO works with MA plans, please email advocacy@naacos.com.

CMS PUBLISHES FINAL PAYMENT RULES
On August 1, CMS issued the FY 2023 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long‑Term Care Hospital (LTCH) Prospective Payment System (PPS) final rule. Of note, CMS finalized:
  • A 4.3 percent increase in hospital payments for FY 2023,
  • A 5 percent cap on any wage index decreased, and
  • Three new health equity measures that hospitals will be required to report in the coming years: Hospital Commitment to Health Equity, Screening for Social Drivers of Health, and Screen Positive Rate for Social Drivers of Health.
CMS also released final rules for other payment systems:

CMS POSTS 2020 QPP EXPERIENCE REPORTS
CMS recently released the 2020 Quality Payment Program Experience Report, summarizing performance in the Merit-Based Incentive Payment System (MIPS) and providing information on Qualifying APM Participants (QPs). Highlights include:
  • Clinicians participating in APM Entities earned the highest average final MIPS scores for 2020.
    • Average scores for APM Entities increased from 2019 to 2020 (92.76 in 2019 to 96.24 in 2020).
    • MSSP accounted for 92 percent of MIPS APM participants.
  • 90.9 percent of MIPS eligible clinicians received a positive MIPS payment adjustment.
    • While performance threshold increased, the Public Health Emergency (PHE) policies in effect at that time contributed to performance.
    • Less than 2 percent of all MIPS eligible clinicians received penalties.
  • The number of clinicians who achieved QP status increased by 40,000; 235,225 achieved QP status.
  • MSSP ACOs average QP threshold scores were 49 percent for payment and 50 percent for patient counts. QP thresholds are scheduled to increase to 75 percent for payments and 50 percent for patients in 2023. NAACOS has been advocating Congress to extend the 5 percent Advanced APM bonus and give CMS authority to set more reasonable QP thresholds.
CMS HIGHLIGHTS LESSONS FROM AHC MODEL
In a recent blog, CMS shared key lessons from the Accountable Health Communities (AHC) Model. The models recently concluded in April and focused on evaluating health-related social needs (HRSN) screening, referral, and navigation. CMS noted how it has incorporated successful elements of the program into other models, including ACO REACH and advance incentive payments in MSSP.

WHAT WE’RE WATCHING

REPORT EXAMINES INTERSECTION OF DATA SHARING AND VALUE-BASED CARE
An Urban Institute report funded by HHS recommends greater financial incentives to support the sharing and integration of clinical and population health data into ACOs. The goal was to identify ways to improve data sharing and integration to help advance value-based care. The report was informed by interviews with 21 organizations.


EDUCATIONAL OPPORTUNITIES

CAN’T ATTEND FALL CONFERENCE IN PERSON? REGISTER NOW FOR LIVE WEBCAST!
Join us September 8–9 for the NAACOS Fall 2022 Conference with optional half-day workshops on September 7. The agenda features leading ACO experts and CMS officials sharing timely and essential information for ACOs.

Individuals unable to attend the conference in person can participate in the live webcast that includes all 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. Register Now!

As always, it’s never too late to attend in person at the Marriott Marquis Washington, D.C. Take advantage of our group rates for both the in-person and virtual conference. To register at the group rate, please contact Emily Perron.

Exhibitor and Sponsor opportunities are still available!
The NAACOS Fall Conference will feature exhibitors with products and services specifically for the accountable care community. Reserve your space today!
Welcome New ACO Member

Wellstar Clinical Partners Medicare ACO, LLC
Marietta, GA
MSSP REPAYMENT MECHANISM SUBMISSION DATE FAST APPROACHING
With the MSSP repayment mechanism date of September 9 fast approaching, join the upcoming NAACOS webinar, Understanding the Mechanics of the MSSP Repayment Mechanism, on August 15 from 3:00–4:00 pm ET to prepare for submission. This webinar is aimed at ACOs going into or increasing their risk tracks and will help you prepare your repayment mechanism documents and submit them. The webinar will feature two ACO leaders who have worked through these processes and can provide valuable information on best practices to successfully obtain and submit your repayment documents. The webinar will include information on each of the options, why you may choose one method over another, and how to obtain and submit the needed documentation. We will also review the calculations CMS uses to determine the required amounts so that you can estimate the amount for your ACO. Register today to join this event!

IN-PERSON LEARNING LABS COMING ON SEPTEMBER 7
Join us in Washington, D.C., on September 7 from 1:00–5:00 pm ET for two NAACOS Learning Labs: the kick-off of our new Medicaid Learning Lab and the continuation of Specialist Integration and Incentives.

As interest grows in how ACOs can participate and be successful in Medicaid, NAACOS is hosting its newest Learning Lab to prepare ACOs for Medicaid contracts. Register now to join the Medicaid Learning Lab kick-off in-person or future virtual sessions. If you are unable to attend the first in-person session but want to be included in future virtual sessions, first sign up then send a follow-up email to Emily Perron.

For participants in the Specialist Integration and Incentives Learning Lab, please email Emily Perron if you plan to attend the in-person meeting on September 7. This meeting will pull together information addressed to date in our two subgroups, update the full group, and gather feedback for next steps.

Please note these are two separate meetings that will take place at the same time as the NAACOS preconference workshops. There is no charge for NAACOS ACO members to attend Learning Lab sessions.

As always, if a representative from your ACO has expertise to present or would like to take a more active role in either of the learning labs, please reach out to Melody Danko-Holsomback, VP of Education.

DATA UPDATES

ACO QUALITY AND HEALTHCARE DISPARITIES
The Institute for Accountable Care, a non-profit research affiliate of NAACOS, is conducting a study of quality in MSSP ACOs, including healthcare disparities among African American, LatinX and Asian/Pacific Islander Medicare beneficiaries. Early results suggest that there is a sub-set of ACOs that excel at addressing disparities in access, care for chronic conditions, and avoidance of acute exacerbations. We are interested in learning more from the leaders in the field: How do you build health equity into your strategic priorities? What care redesign activities support access and patient-centered care? How do you engage clinicians and beneficiaries in this work? If you are interested in sharing your story with IAC/NAACOS and other ACOs, please reach out – we’d love to set up a call to learn about your ACO and share the findings with other ACOs. Contact Jennifer Perloff, perloff@brandeis.edu and Sam Sobul.


AWV STUDY
Are you using annual wellness visits (AWVs) effectively and for high need, complex older adults? Are you using other evidence-based geriatric interventions in your practice? Could you benefit from a structured AWV protocol? If you answered yes to any of these questions, you may be interested in a new PCORI proposal on the effectiveness of AWVs compared to AWVs enhanced with the GRACE model. Participating ACOs will get access to an AWV protocol as well as training and support in the GRACE model, including access to dozens of standardized protocols that can be implemented with older adults needing support with a range of geriatric issues. If you are interested in learning more, please reach out to Jennifer Perloff, perloff@brandeis.edu and Sam Sobul from the Institute for Accountable Care. Thanks!