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 advocacy@naacos.org.
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 ACOREACH@NAACOS.com.
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.
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 advocacy@naacos.com.
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.
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.
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!
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.
