NAACOS DRAFT COMMENTS ON PFS PROPOSED RULE AVAILABLE NAACOS is pleased to provide draft comments on the Calendar Year (CY) 2024 Physician Fee Schedule (PFS) Proposed Rule. The rule includes several positive proposals for improving the Medicare Shared Savings Program (MSSP). In case you missed it, NAACOS provided a detailed overview of the proposed changes during a webinar. Comments are due in three weeks on September 11. We encourage you to use all or portions of our comments in your response. If you have any questions, suggested changes, or additions to the comment letter, please contact advocacy@naacos.com by COB September 5.
WELCOME NEW BUSINESS PARTNERS
LAST CALL: SIGN UP TODAY FOR NAACOS FALL HILL DAY Registration closes Friday, August 25 for the upcoming NAACOS Hill Day on September 20 in conjunction with the NAACOS Fall Conference. This is a great opportunity to engage with your representatives on Capitol Hill and advocate for policies that improve value-based care. Please contact Robert Daley if you have questions. Sign up now to join us!
COMPLETE THE SURVEY ON PATIENT ENGAGEMENT As part of our efforts to support ACOs with patient engagement, NAACOS is surveying ACOs about current patient engagement efforts, challenges and policy barriers, and best practices. These results will be used to support key advocacy efforts such as reforming the MSSP beneficiary notification requirements and expanding available waivers. One or more individuals at each member ACO should receive an email this afternoon from NAACOS Data (data@naacos.com) with a unique link to respond to this brief survey. Only one individual from your organization needs to submit a response. A PDF of the questions is available to help your team collaborate on your organization’s response. Responses are due by COB Friday, August 25. If you have any questions about or issues with the survey, please email Alyssa Neumann.
CONGRESSIONAL UPDATES
CONGRESS PREPARES FOR BUSY SEPTEMBER The House and Senate are still in a district work period. With only a few weeks remaining before lawmakers return to Washington, congressional leaders have begun outlining priorities for the post-Labor Day work period. Discussions are already underway with lawmakers eyeing a short-term continuing resolution (CR) that would prevent a government shutdown at the end of September and extend government funding through early December. This would give leaders more time to work out the significant differences between the spending priorities in the House and Senate. Lawmakers will also likely need to consider a short-term extension of several health programs that will expire at the end of September, including Medicaid Disproportionate Share Hospital (DSH) payments, pandemic preparedness, health workforce, and substance use disorder programs. NAACOS is advocating that Congress include an extension of the advanced APM incentive in the September or December package. A focus of our Fall Hill Day will be to convey this message to lawmakers.
ASK YOUR MEMBERS OF CONGRESS TO COSPONSOR THE VALUE IN HEALTH CARE ACT A bipartisan group of House lawmakers reintroduced legislation last month to improve the MSSP, extend advanced alternative payment model (APM) incentives, and explore the potential of increasing parity between APMs and Medicare Advantage. Help us build support for the bill by asking your representatives to cosponsor. Visit our 2023 congressional priorities page for resources to support your outreach. Please contact Robert Daley for more information on how to engage with your Members of Congress.
NON-PHYSICIAN ASSIGNMENT Representative Derek Kilmer (D-WA) is working with other lawmakers to reintroduce legislation this year that would remove the physician assignment requirement in the MSSP. While NAACOS supports expanding the role of nurse practitioners and physician assistants in ACOs, we continue to advocate with lawmakers that specialty focused non-physician practitioners should not be included in the expansion. We continue to hear concerns from ACOs with multi-specialty practices that an expansion without the proper safeguards could affect alignment and ACOs’ ability to meet benchmarks. If a congressional office reaches out to you to inquire about the benefit or challenges of the legislation, contact Robert Daley for more information.
ADMINISTRATION UPDATES
CHANGES TO ACO REACH ANNOUNCED BY CMMI The Center for Medicare and Medicaid Innovation (CMMI) recently announced numerous changes to the ACO REACH Model, which will take effect in 2024. The changes include:
Applying risk corridors to retrospective trend adjustment (RTA) such that ACOs will only be liable for 50 percent of losses between 4 percent and 8 percent of the RTA and no losses above 8 percent of the RTA;
Adding new variables to the Health Equity Benchmark Adjustment, including a state-based Area Deprivation Index, and providing equal weight to Dual Medicare-Medicaid status/Low-Income Subsidy status;
Expanding the upward Health Equity Benchmark Adjustment to ACOs in the top three deciles, while expanding the downward adjustment to ACOs in the bottom to -$10 per patient per month; and
Phasing in the new risk adjustment model (V28) similarly to how it will be blended for Medicare Advantage plans, while capping the coding intensity factor.
2022 PERFORMANCE RESULTS DELIVERED TO ACOS MSSP and REACH ACOs have received their 2022 performance results. These results are under embargo until CMS makes the data public, which should be in the next few weeks. Once the embargo is lifted, we encourage ACOs to share their results publicly. To help, NAACOS has crafted a media tool kit to provide ACOs with a draft press release and other tips. It is critical that ACOs communicate how this model enables their providers to improve patient care with their communities.
FINAL OPPORTUNITY TO REMOVE ACO PARTICIPANTS CLOSES SOON ACOs applying to participate in MSSP beginning January 1, 2024, and current ACOs making modifications to their ACO participant list through the annual change request cycle must submit any deletions from the ACO participant list by September 5, 2023, at 12:00pm ET. This will also be the final opportunity to remove Skilled Nursing Facility (SNF) affiliate TINs and correct any deficiencies identified by CMS within the Phase 1 RFI-2. More information on the application cycle and key deadlines is available.
2022 MIPS SCORES NOW AVAILABLE CMS recently shared 2022 Merit-Based Incentive Payment System (MIPS) performance and resulting payment adjustment amounts for the corresponding 2024 payment year. Many ACOs are reporting higher scores and payment adjustments than in previous years of up to 8.25 percent. If you are willing to share your performance score and payment adjustment, please email us at advocacy@naacos.com. As the MIPS bonus potential now exceeds the Advanced APM bonus amounts for the first time, NAACOS will continue to advocate with CMS and Congress for better incentives for participation in ACOs and Advanced APMs.
NAACOS DRAFT COMMENTS IN RESPONSE TO BUNDLED PAYMENT RFI NAACOS recently submitted comments in response to the CMS request for information on the design of a future episode-based payment model. NAACOS commented that CMS should adopt the following principles when considering the design of episode-based payment models.
Bolster total cost of care arrangements.
Develop strategies to engage more specialists and other providers in total cost of care arrangements.
Design episodic payment models to complement total cost of care arrangements.
Incentivize the adoption of total cost of care arrangements.
NAACOS will continue to advocate for policies that allow further engagement of specialists in ACO models.
CMMI RELEASES MAKING CARE PRIMARY MODEL RFA Last week, CMMI released the request for applications (RFA) for the upcoming Making Care Primary (MCP) Model, with additional details about applicant eligibility, care delivery requirements, performance assessment, and payment structures. An applicant Office Hour webinar was held on Monday; slides and a recording will be made available on the MCP Model webpage. The application portal officially opens September 5 and closes November 30. Save the date: October 5 from 2:00–3:00 pm ET, NAACOS will host a webinar reviewing the RFA details, discussing the application, and highlighting key considerations for applicants and value-based care leaders in MCP states. Stay tuned for speaker details and registration information! You can also learn more about MCP in this NAACOS summary resource and by joining NAACOS’ Washington Update (September 22, 9:45am ET) during the fall conference next month.
EDUCATIONAL EVENTS
DIVE DEEP INTO FALL CONFERENCE WORKSHOPS In conjunction with the NAACOS Fall Conference on September 20 from 1:00 – 5:00 pm, we will hold three concurrent workshops that take a deep dive into key issues facing ACOs. These workshops require additional registration from the main meeting, they are only available in-person, and you can add them on if you are already registered for the main conference by contacting Emily Perron. The workshops include:
Aligning Your Business Model with CMS’s 2030 Vision for Value-Based Care chaired by Jarvis Leigh, Aledade. In 2021 CMS established a goal to have 100 percent of Medicare beneficiaries in some type of accountable or value-based care arrangement by 2030. We will highlight key areas where MA diverges from MSSP and give you the insights you need to succeed in MA.
How ACOs Drive Specialist Engagement to Improve Patient Outcomes chaired by Vinod Shenai, VillageMD. ACOs will share practical analytical and operational approaches to develop, engage, and manage a preferred network of high performing specialist providers to improve patient outcomes and drive appropriate cost and utilization. We will discuss lessons learned by independent PCP led ACOs as they drive specialist engagement by providing actionable insights to improve specialist performance to enable success in value-based care. We will also understand how a multi-specialty group manages the dynamics and balancing of revenue for its providers and generating shared savings for its ACO. Lastly, we will look over the horizon to understand upcoming industry trends as we review the CMS Innovation Center’s Specialty Care Strategy and share perspectives on next generation episode methodology to evaluate and identify high performing specialist providers.
Quality Reporting for MSSP ACOs – Deep Dive into Digital Quality Measurement chaired by Jennifer Gasperini, NAACOS. This workshop will explore multiple facets of MSSP quality reporting. NAACOS staff will provide an in-depth discussion on new quality proposals in the 2024 proposed Medicare Physician Fee Schedule rule. ACOs will also share their perspectives on how they are evaluating reporting options, addressing complex patient matching and data aggregation, leveraging IT teams and internal platforms and engaging independent practices in quality reporting. Speakers will also discuss fast healthcare interoperability resources and how standards affect ACO quality improvement and reporting activities.
The main conference will take place September 21–22 at the Marriott Marquis Washington, D.C. See the full agenda now!
WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE
The Health Care Payment Learning & Action Network (HCP-LAN) released a Multi-Payer Alignment Blueprint to support cross-state alignment of health care transformation efforts and build a foundation for national alignment.
In this Health Affairs Podcast, guest Meena Seshamani, director of the Center for Medicare, discusses the evolution of Medicare Advantage, value-based care programs, and more.
The National Quality Forum announced it is joining forces with The Joint Commission in a strategic affiliation.
