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ASK CMS TO DELAY QUALITY CHANGES AND REPEAL PI REQUIREMENTS
NAACOS continues to be concerned about CMS’s approach for updating the quality and certified EHR technology (CEHRT) requirements for ACOs. We are asking ACOs and other stakeholders to sign on to a letter asking CMS to delay quality changes and repeal promoting interoperability (PI) requirements scheduled to take effect in 2025. In our letter, we ask CMS to:
- Delay sunsetting the Web-Interface and Merit-based Incentive Payment System (MIPS) Clinical Quality Measure (CQM) reporting methods in 2025 for three additional years to align with the timeline required in the CMS Interoperability and Prior Authorization Final Rule.
- Assure ACOs that the Medicare CQM option will be available for the foreseeable future until dQM reporting is successful.
- Repeal new PI requirements for MSSP ACOs, as well as the increase in CEHRT requirements for Advanced APMs taking effect in 2025.
Help us advocate for these important changes by have your organization and participant practices sign-on to the letter by close of business on September 3. For more information contact Jennifer Gasperini.
NAACOS DRAFT PFS COMMENTS AVAILABLE
NAACOS is pleased to provide draft comments* in response to the Calendar Year (CY) 2025 Medicare Physician Fee Schedule proposed rule. NAACOS supports several positive key positive changes for ACOs, including:
- Actions to mitigate the impact of significant, anomalous, and highly suspect (SAHS) billing activity on MSSP ACOs
- New advanced primary care management codes for bundled primary care services
- Prepaid shared savings and a health equity benchmark adjustment in MSSP
- Considerations for a higher risk track in MSSP
However, we remain concerned that CMS is unwavering in the transition to more burdensome quality measurement reporting and has not adequately addressed the benchmark ratchet. Our comments urge CMS to address these critical issues.
We encourage members to use our comments in their responses. If you have suggested edits or additions to NAACOS comments, please contact Aisha Pittman.
*You must be logged into the NAACOS website in order to access the draft comments.
SUBMIT QUESTIONS/TOPICS FOR CMS TOWN HALL
We close each NAACOS conference with a CMS Town Hall session which provides an opportunity for attendees to have an open dialogue with leadership at CMS. Submit your questions and topics for discussion to [email protected].
CONNECT WITH PAYERS AND PROVIDERS FOCUSED ON VBC ARRANGEMENTS
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 in value-based care (VBC). This forum is scheduled for October 16 from 1:00 – 5:00 pm ET. Separate registration is required from the main meeting.
NEW NAACOS RESOURCES AVAILABLE
- An overview of the Performance Year (PY) 2025 CEHRT requirements for ACOs. While we continue to oppose these changes, the recent guidance published addresses several of the concerns and recommendations NAACOS previously raised. The exclusions and ability to report a PI score of “zero” should create a pathway for maintaining practices who fail to meet the CEHRT requirement in the ACO. For more information contact Jennifer Gasperini.
- Brief recorded webinars that take a deep dive into how VBC entities and practices are using the best practices outlined in the playbook on Creating a Sustainable Future for Value-Based Care Payment
LAWMAKERS PREPARE FOR BUSY END-OF-YEAR SPRINT
Congress returns the week of September 9, and leaders will have three weeks to pass another short-term extension of government funding prior to the election. Additionally, congressional committees are discussing how to address a wide range of health care priorities before January, including:
- Offsetting physician payment cuts and extending advanced APM incentive payments.
- Extending telehealth and hospital at home programs.
- Offsetting DSH payment cuts and other Medicare extenders policies.
- Pharmacy benefit manager (PBM) reform and health care price transparency.
- Medicare Advantage prior authorization reform.
UPDATES FOR MSSP PARTICIPANTS
- The deadline to submit change requests for 2025 is next week on September 5 at 12:00 pm ET. ACOs will have until then to respond to the Phase 1 RFI-2, making any final changes to ACO participant TINs and SNF affiliate TINs, uploading executed agreements and merger/acquisition documents, and submitting a participation options change request, including changing beneficiary assignment methodology. More information available on the MSSP Application Types & Timeline webpage and in the Application Toolkit.
- The preliminary rate book for the ACO Primary Care Flex (PC Flex) Model is now available. CMS notes that the preliminary rate book does not yet include the FQHC/RHC add-ons, which will be announced later in 2024. ACOs pursuing the model can use the rate book to predict their prospective primary care payments (PPCP) paid between January and June 2025. If you have feedback on the rate book or other model updates, reach out to Alyssa Neumann.
OTHER CMS UPDATES
- The Center for Medicare and Medicaid Innovation outlined its data sharing strategy in a Health Affairs Forefront article. The strategy notes the Innovation Center will focus on promoting access to CMS data, incorporating data sharing in early model design, focusing on standards, investing in tools, and enhancing CMS data capabilities.
- The administration announced 10 Medicare Part D drugs that will be subject to price negotiations starting in 2026, noting negotiations would have collectively save $6 billion if in done last year. Part B drugs will start to be eligible for negotiated prices starting in 2028.
NETWORK AND LEARN FROM PEERS AT THE FALL CONFERENCE
Join us in Washington, D.C., on 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.
Network and learn from peers at our affinity group meetings on Thursday afternoon from 4:00 – 5:30 pm. Our affinity groups are broken into professional roles and include:
- Clinical and CMO
- Quality
- Legal and Compliance
- Executive
- Operations
- Data and Analytics
These meetings are meant to be peer-to-peer discussions around current ACO and population health issues. These sessions are not open to NAACOS Partners. See the full agenda now!
DIAMOND SPONSORSHIPS STILL AVAILABLE
Interested in sponsoring the Robbie Pearl book signing or holding a Friday breakfast session? NAACOS Partners are the only non-ACOs allowed to attend, exhibit and sponsor NAACOS conferences. To sign up for sponsorships, please contact Emily Perron.
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WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE |
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