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NAACOS RESPONDS TO RFI ON COMPLEX PATIENTS
NAACOS provided comments in response to the Physician-focused Payment Model Technical Advisory Committee (PTAC) request for input (RFI) on addressing the needs of patients with complex chronic conditions or serious illnesses in population-based total cost of care models. NAACOS recommended that policymakers design specific program policies to account for high-cost, high needs beneficiaries who are significantly different from the average traditional Medicare beneficiary, including financial methodologies, attribution models, and quality measurement.
NEW NAACOS RESOURCES
- Information Blocking. The Department of Health and Human Services (HHS) finalized information blocking disincentives, or penalties, that will be imposed on health care providers effective July 31, 2024. This resource explains what CMS considers to be information blocking practices and the potential penalties ACOs and clinicians could face. NAACOS was pleased to see CMS clarify that enforcement discretion will be used when applying penalties to ACOs.
- MSSP ACO Revenue Designations. NAACOS updated our assessment of ACO revenue designations, which CMS uses as a proxy for ACOs’ access to capital and ability to control spending. NAACOS has opposed the “low revenue” or “high revenue” policies since first established in the Pathways to Success final rule. The updated assessment uses 2022 data to examine differences between high versus low revenue ACOs. CMS has recently expanded on this policy by limiting certain program options to low revenue ACOs. NAACOS is continuing to advocate to remove this designation. Reach out to Alyssa Neumann if you’re interested in engaging in this effort.
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CMS FINALIZES TEAM MANDATORY BUNDLED PAYMENT MODEL
In the final 2025 Inpatient Prospective Payment System (IPPS) rule, CMS finalized the Transforming Episode Accountability Model (TEAM). TEAM is a mandatory bundled payment model that will be required for acute care hospitals located in selected geographic regions, starting January 2026. The model will run for five years and will test incentives for coordination between providers during a surgery and the services provided 30 days post-surgery for the following procedures: lower extremity joint replacement, surgical hip and femur fracture treatment, spinal fusion, coronary artery bypass graft, and major bowel procedure. TEAM will have three participation tracks with varying levels of risk:
- Track 1 – no downside risk, available for one year (or three years for safety net hospitals)
- Track 2 – lower levels of risk and reward (available years 2–5)
- Track 3 – higher levels of risk and reward (available years 1–5)
TEAM will allow beneficiaries aligned to an ACO to also be included in TEAM to promote provider collaboration. NAACOS will hold a webinar on September 5 at 2:00 pm ET to review key details of the new model.
NEW PI/CEHRT FAQS ISSUED FOR MSSP AND REACH ACOS
In the ACO Spotlight Newsletter issued August 9, CMS published new Frequently Asked Questions (FAQs) on Promoting Interoperability (PI) requirements for MSSP ACOs. The FAQs note that the small practice exclusion will apply to practices in ACOs and provide additional clarity around consequences for non-compliance, which can lead to ineligibility for shared savings. ACOs can access the ACO Spotlight Newsletter in the ACO-MS (refer to Issue 15). The REACH model also recently shared guidance with REACH ACOs concerning Certified EHR Technology (CEHRT) compliance requirements for Performance Year (PY) 2025. REACH ACOs will be required to attest that their 2025 providers will use CEHRT for at least one quarter of PY 2025 or qualify for an exception. NAACOS is requesting clarification on what exceptions will apply for REACH ACOs, and we are advocating for parity with those applied to MSSP. NAACOS will continue to advocate for removal of this requirement, which is burdensome and does not add value for patients.
ACO PRIMARY CARE FLEX UPDATES
- Applications Due Next Week. ACOs applying to participate in the ACO Primary Care Flex (PC Flex) Model will have until 11:59 pm ET on August 23, 2024, to submit the supplemental PC Flex questionnaire and be considered for model participation. Details on the PC Flex application questionnaire and on the PC Flex Model are available in the Request for Applications and on the model webpage. ACOs applying to participate in PC Flex remain subject to all MSSP application deadlines and requirements. The Phase 1 RFI-2 response period for the MSSP application and change request cycle will be open from August 22 through September 5 at 12:00 pm ET. This will be the last opportunity to remove ACO participants and/or SNF affiliates to your ACO for PY 2025. Additional information on the application deadlines can be found on the Application Types & Timeline webpage, and in the Application Reference Manual.
- Updates and Changes to Financial Methodology. This week CMS announced changes and updates to the PC Flex Model’s financial methodology:
- Claims reductions will be delayed until July 1, 2025. Participants will still receive the one-time advance shared savings payment and the enhanced portion of the prospective primary care payment (PPCP) beginning January 1, 2025.
- A preliminary Flex Model rate book will be published later this month using base years 2021–2023. This preliminary rate book will be used for the first half of 2025. The updated rate book is expected to be published in the second quarter of 2025 using base years 2022–2024. CMS expects there will be an additional updated rate book for 2026 to reflect the full CMS-HCC model, version 28.
- An updated example calculations workbook has been published to reflect how CMS will treat the Health Equity Adjustment (HEA) at financial settlement. The HEA will be included in total expenditures and CMS will apply a Health Equity Credit equal to the ACO’s total HEA for the performance year. The Health Equity Credit will be added to the Total Enhancement Credit to calculate the Total ACO PC Flex Settlement Credit, which is added to the earned performance payment or payment due to CMS.
CORRECTION: ACO REACH’S 2025 CHANGES ANNOUNCED
In our August 1, 2024, newsletter, NAACOS misstated the discount of the ACO REACH Model in an article highlighting 2025 changes to the model. The discount will increase from 3 percent in 2024, to 3.5 percent next year, and is planned to increase to 4 percent in 2026.
CMS BEGINS RELEASING FINAL 2025 PAYMENT RULES
- Inpatient Hospital— CMS is updating IPPS payments by 2.9 percent payment (an estimated increase of $2.9 billion).
- Inpatient Psychiatric— CMS is updating IPF payments by 2.5 percent (an estimated increase of $65 million).
- Skilled Nursing— CMS is updating SNF payments by 4.2 percent (an estimated increase of $1.4 billion).
- Hospice—CMS is updating hospice payments by 2.9 percent (an estimated increase of $790 million).
REMINDER: 2024 NOTICE OF APM INCENTIVE PAYMENTS
Earlier this summer, CMS began paying out advanced APM incentive payments to qualifying QPs. On July 1, 2024, CMS published a list of unpaid QPs to whom the agency has been unable to disburse APM incentive payments. If any practices or QPs in your ACO have not received their APM payment for PY 2022, please check the CMS list and complete the 2024 Billing Information Collection Form and submit it to the Quality Payment Program (QPP) Help Desk at [email protected] no later than September 1, 2024.
GAIN AN EXTRA DAY OF LEARNING WITH PRE-CONFERENCE WORKSHOPS
Join us in Washington D.C, October 16–18 at the Marriott Marquis for the Fall 2024 Conference. The agenda features leading value-based care experts and CMS officials sharing timely and essential information for ACOs, including Jon Blum, Principal Deputy Administrator and Chief Operating Officer at CMS, and author, Robbie Pearl.
Register Now!
Pre-conference workshops will be held concurrently on Wednesday, October 16 from 1:00–5:00 pm ET. These workshops require separate registration from the main meeting. The three concurrent workshops will be:
- Optimizing Your Payer-Provider Engagements led by Diwen Chen, NAACOS
- Clinical Best Practices/Successful Disease Management Programs led by Jen Brady, Advocate Health
- Fundamentals of ACO Success led by Bob Rauner, Healthy Nebraska
We still have a few remaining tabletops and sponsorships available for the fall conference! Partners interested in exhibiting or sponsoring should contact Emily Perron.
PAYER-PROVIDER FORUM AT NAACOS FALL PRE-CONFERENCE
NAACOS is hosting a Provider-Payer Forum at the NAACOS Fall Conference. The purpose of this pre-conference session is to bring together NAACOS members and payers to identify best practices, challenges, and solutions for building optimal payer and provider engagements. This forum is part of the NAACOS Fall Pre-Conference event on Wednesday, October 16 from 1:00 – 5:00 pm ET. Separate registration is required from the main meeting.
SPONSORED WEBINAR NEXT WEEK ON AI
NAACOS Business Partner, Innovaccer, will be sponsoring a webinar next Thursday, August 22 at 2:00 PM ET. Register today for AI in Value-Based Care – The Hype, The Hope, and The Reality.
AUGUST 23 PRACTICE TRANSFORMATION LEARNING LAB POSTPONED
NAACOS has postponed the August 23 Practice Transformation Learning Lab meeting and topic discussion. We will pick up the topic of “Understanding Available ACO Data” during our regularly scheduled September 27 meeting. For those who have already registered for the Practice Transformation Learning Lab and not received the updated appointment for your calendar, please reach out to Karen Fetterolf, NAACOS Education Manager, at [email protected]. If you have not registered for this Learning Lab series sign up if you would like to receive future meeting dates.
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WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE |
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