NAACOS Newsletter for Members and Partners August 25, 2022

NAACOS Logo Newsletter for Members
and Partners
August 25, 2022
Table of Contents

NAACOS ADVOCACY

Submit Comments in Response to CY23 MPFS Proposed Rule
Catch On-Demand Webinar: MSSP vs. ACO REACH Financials
NAACOS Launches Monthly Government Relations Advocacy Calls

CONGRESSIONAL UPDATES

Drug Pricing Bill Signed into Law

ADMINISTRATION UPDATES

MSSP ACOs Received Embargoed 2021 Performance Results
CMS Releases Names of Provisionally Accepted REACH ACOs
CMS Tells Providers to “Prepare” for the End of the COVID-19 PHE
Reminder: CMS Is Requesting Billing Information for Certain QPs
CMS Posts Final 2021 MIPS Scores

EDUCATION OPPORTUNITIES

Conference Registration Still Open, In-Person and Virtual

NAACOS ADVOCACY


SUBMIT COMMENTS IN RESPONSE TO CY23 MPFS PROPOSED RULE
NAACOS has drafted a detailed comment letter in response to the proposed 2023 Medicare Physician Fee Schedule (MPFS) rule. This regulation includes many positive changes to the Medicare Shared Savings Program (MSSP), including the glidepath to risk, changes to financial methodologies, advance shared savings payments for certain ACOs, and an alternative quality performance standard. It is critical that CMS hear directly from ACOs, and we encourage members to use all or portions of our letter in your comment submissions. If you have any questions about our draft letter, please contact [email protected]. CATCH ON-DEMAND WEBINAR: MSSP VS. ACO REACH FINANCIALS
If you missed this week’s NAACOS webinar on understanding your participation options between MSSP and ACO REACH, you can still catch it on-demand. The webinar reviewed the financial methodology and provided an actuarial comparison between MSSP and REACH. This followed the recent release of the financial specifications for the ACO REACH Model. The CMS Innovation Center’s Corey Rosenberg, ACO REACH Model lead, joined as a speaker and answered a few questions as well. If you have follow-up questions or would like more information about ACO REACH, contact NAACOS staff at [email protected].

NAACOS LAUNCHES MONTHLY GOVERNMENT RELATIONS ADVOCACY CALLS
Earlier this summer, the NAACOS government affairs team began holding monthly calls for our members’ in-house or contracted government relations teams. These calls are 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 Thursday, September 15. Contact Aisha Pittman or Robert Daley to have your organization’s in-house or external government relations team join.

Welcome New Business Partners
Alliant Insurance Services
As one of the nation’s leading insurance brokerages, Alliant Insurance Services is dedicated to driving value and expertise in Value-Based Healthcare reimbursement and delivery-service models.
alliant.com
Somatus
Somatus partners with nephrology and primary care groups, leading health plans, and health systems to provide integrated care for patients with, or at risk of developing, kidney disease.
somatus.com
Videra Health
Videra Health is an FDA-registered digital health platform, and the leader in video-based assessments, screenings, and check-ins.
viderahealth.com
 
CONGRESSIONAL UPDATES

DRUG PRICING BILL SIGNED INTO LAW
On August 16, President Biden signed the Inflation Reduction Act (IRA) into law, which establishes a Medicare drug pricing negotiation program for certain high-priced pharmaceuticals, provides rebates for Medicare Part B or D drugs when prices increase faster than inflation, and lowers out-of-pocket thresholds for certain Medicare Part D drugs. The law also extends Affordable Care Act (ACA) tax subsidies through 2025.

With consideration of the IRA now complete, lawmakers will return to Washington in September to begin laying out priorities that need to be addressed before the end of the year. NAACOS will be strongly advocating for Congress to extend the 5 percent Advanced APM bonus. Please support these upcoming activities:
  • Sign-on to the national stakeholder, ACO, and physician practice letter that asks congressional leadership to extend the bonuses. You will receive information about signing on by the end of the week.
  • Join a congressional briefing on extending the bonuses on September 29. Registration will be available next month.
Compliance Manual

ADMINISTRATION UPDATES

MSSP ACOS RECEIVED EMBARGOED 2021 PERFORMANCE RESULTS
CMS has sent MSSP ACOs their embargoed 2021 performance results. As always, the results are embargoed. CMS typically lifts the embargo a few weeks to a month later. The PHE was in effect last year, so CMS waived any shared losses. Additionally, the quality results will be displayed differently this year because of different reporting methods (electronic clinical quality measure [eCQM], Merit-based Performance System clinical quality measure [MIPS CQM] or Web Interface) and different measures sets associated with the reporting mechanisms. Lastly, ACOs were awarded the higher of their own quality score or the mean score.
  • Last year was a banner year for MSSP with ACOs generating $4.8 billion in gross savings and $2.1 billion after accounting for shared savings payments. NAACOS encourages members to publicize their results. Use our media kit to help tout your savings once the embargo is lifted.
  • NAACOS has heard from ACOs whose final settlements varied drastically from projections because of a combination of the rural glitch, a cap on risk score growth, and the lack of a cap on regional risk scores. These policies overall caused ACOs’ final benchmarks to drop significantly. If you have seen similar issues, please let us know at [email protected].
CMS RELEASES NAMES OF PROVISIONALLY ACCEPTED REACH ACOS
Last week the CMS Innovation Center posted the names of the 110 provisionally accepted applicants for the ACO REACH Model as well as those participating in the third Implementation Period, which started earlier this month. The Innovation Center also published an updated version of its application fact sheet and FAQs. We congratulate all who were accepted. It is unusual for the Innovation Center to post the names of anyone other than who is participating in its models, but the agency and model are under great political pressure and are erring on the side of transparency. The Innovation Center did not publish the names of those who applied and weren’t accepted. NAACOS continues to follow the negative rhetoric the model is receiving and counter it when appropriate.

Apply for a new job!

CMS TELLS PROVIDERS TO “PREPARE” FOR THE END OF THE COVID-19 PHE
In a recent blog post, CMS outlined a high-level “roadmap” for the end of the COVID-19 Public Health Emergency (PHE), telling providers to “prepare for the end of these flexibilities as soon as possible.” The PHE is scheduled to expire on October 13, but NAACOS is expecting it to be extended at that time, either through the end of the year or for another 90 days into January. The administration has promised at least a 60-day notice of the PHE expiring. In the meantime, CMS outlined its thinking about the PHE’s expiration and how it plans to support providers and monitor data on certain PHE-era flexibilities. While Congress granted a 151-day extension of telehealth flexibilities, CMS is encouraging providers to “to prepare to return to normal operations.” A series of fact sheets notes what is set to lapse at the end of the PHE, including those within MSSP around the waiving of shared losses, quality reporting, and removing of COVID-19 expenditures from financial calculations. Please refer to the NAACOS COVID-19 page for more information.

REMINDER: CMS IS REQUESTING BILLING INFORMATION FOR CERTAIN QPS
On August 10, CMS issued an advisory in the Federal Register to alert certain clinicians who are Qualifying APM participants (QPs) and eligible to receive an Advanced APM Incentive Payment that CMS does not have the current billing information needed to disburse the payment. The list of QPs with unverified billing information, along with instructions on how to update billing information is available online. QPs that have not received payments must update their information no later than Tuesday, November 1.

CMS POSTS FINAL 2021 MIPS SCORES
CMS recently posted final MIPS scores for Performance Year 2021, which dictate 2023 payment amounts. For ACOs subject to MIPS, those with the Security Official role can access the Quality Payment Program website to view 2021 performance feedback including the final score and resulting payment adjustments. More information is available in this CMS FAQ.

Welcome New Associate ACO Member

Responsive Care Solutions
Sarasota, FL
Welcome New Multi-ACO Member

Vytalize Health
Headquarters: Hoboken, NJ
EDUCATION OPPORTUNITIES

CONFERENCE REGISTRATION STILL OPEN – IN PERSON AND VIRTUAL
Join us September 8–9, 2022, for the NAACOS Fall Conference at the Marriott Marquis in Washington, D.C. with optional half-day workshops on September 7 for in-person participation only. The agenda will feature leading ACO experts and CMS officials sharing timely and essential information for ACOs.

Check out the agenda!

Two pre-conference workshops on Wednesday, September 7, from 1:00 pm to 5:00 pm can enrich your conference learning. The two workshops will focus on:
  • ACO REACH Compliance and Waivers chaired by Beth Patak, Equality Health
  • Preparing for eCQM Reporting chaired by Anna Taylor, MultiCare Connected Care
Individuals unable to attend the conference in-person can participate in the live webcast of the conference. The live webcast 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!

Register Now for Live Webcast!

As always, it’s never too late to register for in-person at the Marriott Marquis Washington, D.C! Take advantage of our group rates! We are offering group rates for both the in-person and virtual conference.

To register at the group rate, please contact Emily Perron.