WINTER BOOT CAMP AND SPRING CONFERENCE REGISTRATIONS NOW OPEN Winter Boot Camp February 7 – 8, 2022 Orlando Airport Marriott Lakeside
NAACOS Winter 2022 Boot Camp provides expert insight into core competencies for ACOs and DCEs. Boot camp faculty will present essential resources and policy updates as well as the basics on successful care management and resource allocation. This year’s boot camp has been extended to two full days this year and is being held IN-PERSON only. A detailed schedule and agenda are available! Register Now! **Boot camps are not open to business partners. Space is limited to 110 people.**
Spring Conference April 27 – 29, 2022 Hilton Baltimore Inner Harbor
Hear from leading ACO experts and CMS officials sharing timely and essential information for ACOs and DCEs at the Spring 2022 Conference. register before March 4 for the conference and receive a discount of $300 per person. Can’t attend in person? Register for our live webcast before March 4 and receive a discount of $100 per person. We are offering group rates for both the in-person and virtual conference. To register at the group rate, please contact Emily Perron.
The Spring 2022 Conference will feature exhibitors with products and services specifically for the ACO community. NAACOS Partners are the only non-ACOs allowed to attend, exhibit, and sponsor NAACOS conferences. Reserve your space today!
NAACOS Resource Review: Annual Wellness Visits
NAACOS has received a flurry of inquiries on annual wellness visits (AWVs), such as how to engage beneficiaries and how to operationalize both in-person and virtual visits. We are currently researching answers to the questions posed during the recentAWV webinarand hope to have those posted within a week.
In the meantime, we would also like to remind members of our resources on AWVs currently posted on the NAACOS website. These include policy updates related to the public health emergency and use of patient reported information, as well general telehealth flexibilities and rules under the current PHE described inNAACOS Telehealth PHE Summary. For additional resources, use the search feature at the top right corner of the NAACOS webpage and enter AWV or Annual Wellness Visit to pull up pertinent information previously posted, such as the resources described above. If your ACO is interested in participation in future research or collaborative opportunities, please contactperloff@brandeis.edufor more information.
CONGRESS CAREENS TOWARD YEAR END Congress returned this week from recess with only nine scheduled legislative work days remaining between now and the end of the year. The Senate will resume working on the National Defense Authorization Act (NDAA) and consider member amendments. Congress also needs to take action on a stopgap bill to keep the government funded past December 3. Congress must also raise the debt limit around December 15, according to Treasury Secretary Janet Yellen. At the same time, Democrats are aiming to proceed with passing the $2.2 trillion “Build Back Better Act” (BBB) before lawmakers return home for the holidays. This week the Senate will begin the process of working with the Parliamentarian regarding the application of the Byrd Rule, which precludes the inclusion of extraneous provisions in reconciliation measures, to the BBB.
DON’T MISS OUR WEBINAR ON UNDERSTANDING NEW QUALITY REQUIREMENTS NAACOS will hold a webinar on December 16 at 1-2pm ET outlining new quality requirements for MSSP ACOs. Under the new APM Performance Pathway (APP) requirements, ACOs must transition to electronic clinical quality measures (eCQMs) by 2025. In this webinar, NAACOS staff will review quality reporting and scoring changes under the new APP requirements for ACOs. NAACOS Quality Committee Chair, Megan Reyna will also review key operational considerations for ACOs to consider when preparing for these changes. Register today!
CARE COMPARE PREVIEW PERIOD NOW OPEN The Care Compare preview period is now open for ACOs. Care Compare, previously called Physician Compare, allows consumers to view quality data about Medicare clinicians, practices, and ACOs. The preview period opened November 15 and will close on December 14. MSSP and Next Generation ACOs can view their performance information or by viewing 2020 Quality Performance Reports. If you have any questions about public reporting for Care Compare, CMS advises contacting the Quality Payment Program (QPP) Service Center at 1-866-288-8292 or by e-mail at QPP@cms.hhs.gov.
Welcome New Members
Community Healthcare Partners ACO, Inc. Munster, IN
Zia ACO Taos, NM
NAACOS RESOURCES ON THE FINAL 2022 MPFS RULE As ACOs prepare for 2022, it’s critical to understand upcoming policy changes affecting the Medicare Shared Savings Program (MSSP) as well as adjustments to Medicare physician payments. NAACOS developed an in-depth analysis of the lengthy and complex final 2022 Medicare Physician Fee Schedule (MPFS) Rule to walk through these important policy updates. Additionally, NAACOS hosted a webinar on the rule, which is now available. Both review critical quality changes for MSSP ACOs, key payment policies, and QPP updates for 2022, among other issues.
CMS ANNOUNCES FINAL DECISION ON SIP COMPONENT OF PCF This week, CMS announced that, after careful consideration, the agency will not be moving forward with the Seriously Ill Population (SIP) Component of the Primary Care First (PCF) Model. PCF is a voluntary, multi-payer five-year payment model offering enhanced payments to support advanced primary care. The first cohort began in 2021, and the second cohort is set to start in 2022. The SIP Component within the model was designed to support an intensive, time-limited intervention specifically for patients with serious illness who lack primary care providers or are experiencing fragmented care. After initial delays, the SIP Component was set to launch April 1, 2021, but was then delayed further by the agency in March, noting ongoing work with the Innovation Center to ensure that beneficiaries facing serious illness have access to high-quality, person-centered care. Importantly, SIP proposed a new method of beneficiary outreach to identify and attribute eligible beneficiaries. On November 30, the agency announced that it had concluded that the proposed outreach method was unlikely to result in sufficient beneficiary uptake, and therefore it would not be moving forward with the model option. The Innovation Center will continue to explore new interventions to improve care for seriously ill beneficiaries.
WEBINAR RESCHEDULE NOTICE The business partner sponsored webinar, Managing to the New Medicare Patient: Driving New Care Delivery Models with Post-Acute Data Transparency, has been rescheduled for December 16 from 2:00–3:00 pm ET. The baby boomer generation has already begun to age into Medicare and the number of beneficiaries is projected to increase to over 80 million—meaning more people than ever before will rely on the healthcare system. In turn, this new Medicare population will drastically shift the current care delivery models and drive higher demand for long-term care services. So how can ACOs and DCEs prepare for this new Medicare patient? Leading the consumerization of health care, this generation’s knowledge of and preferences about real-time access to healthcare data, aging, and quality of life are much different than their parents. During this presentation, we will discuss the importance in establishing new care delivery models and standardizing care within your post-acute network. Insights will also be provided into how post-acute data transparency will play an integral role in delivering the care and transparency that this new Medicare patient will require. ACO members and non-members can register for this webinar for free. This webinar is not open to Business Partners.
DIRECT CONTRACTING RESOURCES AND RECORDINGS AVAILABLE NAACOS has scheduled its next Direct Contracting Learning Discussion for December 17 at 2:00 pm ET. The event is meant for DCEs to share feedback, questions, concerns, and points of interest. The meeting will take place over Zoom (passcode: 001359). Advance registration is not required, but we are asking that all participants display their full name in the meeting so that speakers and other participants know who is on the call. If you have issues you’d like to raise, please share them with DirectContracting@naacos.com. Please refer to the article at the bottom of this newsletter to read about important Direct Contracting clarifications from CMS following our last learning discussion.
DCEs can find a wealth of information on NAACOS’s stand-alone Direct Contracting page, including our November Learning Discussion and the Participation Agreement for Performance Year (PY) 1, which is a popular document to reference. There are also additional member-only resources such as our overview of financial updates and PY2 Participation Agreement from this fall. NAACOS also lists all of its advocacy letters and statements, including correspondence from July and April with Innovation Center Director Liz Fowler making detailed recommendations on improving Direct Contracting.
CMS DELIVERS Q3 REPORTS TO MSSP ACOS CMS recently made available the PY 2021 Quarter 3 (Q3) report package to MSSP ACOs, which was released through the Data Hub in the ACO management system (ACO-MS). The report package includes, among other items, the Assignment List Report (ALR), Assignment Summary Report (ASR), Aggregate Expenditure/Utilization Report (EXPU), Beneficiary Expenditure Utilization Report (BEUR), and Non-Claims Based Payment File (NCBP). As ACOs review these report packages, NAACOS encourages members to discuss key takeaways or pose questions to your peers on the NAACOS ACO Executive listserv.
LINC TO ADDRESS SOCIAL NEEDS ACT INTRODUCED IN THE HOUSE Last week, Representatives Kildee (D-MI), Walorski (R-IN), Blunt Rochester (D-DE), and Hudson (R-NC) introduced the Leveraging Integrated Networks in Communities (LINC) to Address Social Needs Act (H.R. 6072). This bipartisan legislation will provide upfront funding to states in order to facilitate cross-sector data sharing and coordination, and to measure the impact of social interventions on health outcomes, healthcare spending, and population health. The funds are intended to help states to build statewide or regional collaborations to better coordinate health care and social services. This includes connecting individuals with social needs such as food, housing, or transportation assistance, the most common nonmedical needs being addressed by ACOs. Similar legislation (S. 509) was introduced in the Senate by Senators Sullivan (R-AK) and Murphy (D-CT) earlier this year.
GAO PUBLISHES REPORT ON RURAL APM PARTICIPATION A government report cited a lack of financial support, including upfront costs and ability to take on risk, as reasons more rural providers aren’t transitioning to ACOs and other alternative payment models. The report from the Government Accountability Office, also found that ACOs were not available to a lot of providers serving rural and underserved communities either because of the 5,000-beneficiary minimum or geography. Other barriers include a lack of data analytics, other IT limitations, and staff. NAACOS was one of 18 organizations interviewed for the report, which was mandated by the Medicare Access and CHIP Reauthorization Act to better inform Congress about the status of APM participation by rural providers and the challenges they face. We continued to advocate for a continuation of the ACO Investment Model, which provides upfront money to help start ACOs that’s paid back through shared savings. The full report is available.
INNOVATION CENTER PROVIDES GUIDANCE ON MULTIPLE DIRECT CONTRACTING POLICIES During a recent NAACOS Direct Contracting Learning Discussion webinar, participants raised questions and concerns about several model policies. NAACOS reached out to the Innovation Center and received the following helpful clarifications:
Fee Reduction Agreements Global and Professional Direct Contracting Fee Reduction Agreements do not require individual providers and can be executed by the TIN. The November 12 model newsletter included confusing language that the Innovation Center realizes could be misinterpreted. The center did not intend to state that the Fee Reduction Agreement must be signed at the individual level. Section 12.02.E.3.a of the Participation Agreement is correct as written: “The written confirmation of consent required under this Section 12.02.E must be in the form of a completed Direct Contracting Model: Fee Reduction Agreement signed by an individual legally authorized to act for the entity through whose TIN the individual or entity bills Medicare. CMS may provide to the DCE template language for the Direct Contracting Model: Fee Reduction Agreement. The DCE shall use any template language for the Direct Contracting Model: Fee Reduction Agreement provided by CMS.”
Paper-based Voluntary Alignment (PVA) Members expressed concern that beneficiaries included in the November 18, 2021, PVA submission would not be aligned for January 1, 2022, and PVA forms for those beneficiaries would need to be re-executed. The Innovation Center clarified that valid PVA attestations submitted in the November 18, 2021, deadline will be counted in the mid-December aggregate alignment estimate and will also count for PY 2022 alignment effective January 1, 2022 (see table below). The November 18, 2021, PVA deadline, like all PVA deadlines, was to submit attestations to take effect at the next alignment run (in this case, the run for January 1, 2022).
Reliability of November and December Alignment Reports Members expressed confusion about (1) whether the exclusions/eligibility checks will be the same for November and December reports; and (2) whether Medicare Advantage (MA) lives will be pulled from either. Some DCEs heard they should expect a 20 percent reduction in beneficiary count between the November and December reports but are not sure what would account for that reduction and whether they should then expect another reduction come January.
As the table below notes, the eligibility checks listed in the footnote, including the MA check, will be applied to both the November and December checks. The only difference is that for the November check, we will be using data as of October 1, 2021, and, for the December check, CMS will use data as of November 1, 2021. CMS expects only a minor (~1 percent) change in alignment numbers between the November and December checks. The 20 percent reduction discussion stems from last year: for PY 2021, CMS gave an initial aggregate alignment estimate without applying any eligibility checks, with the rationale that there was more time between the alignment run and the final ‘proxy’ check. This year, because there is less time between the two, and to avoid confusion caused by last year’s approach, CMS applied all eligibility checks (except for Medicare as Secondary Payer, as noted) at the outset to the first alignment estimate (November); this should prevent a meaningful drop in the second estimate (December) due to eligibility.
The following table includes the specifications for what is included in each aggregate alignment estimate:
Specification
Early November estimate
Mid-December estimate
January 2022 (PY 2022) alignment
Beneficiaries claims-aligned for PY 2022
Yes
Yes
Yes
Beneficiaries voluntarily aligned to your DCE using Medicare.gov as of:
9/30/21
10/31/21
10/31/21
Beneficiaries voluntarily aligned to your DCE via paper-based voluntary alignment, in the submission due:
08/13/2021
11/18/21
11/18/21
Model-eligible* as of:
10/1/21
11/1/21
1/1/22
*The beneficiary must be: alive; not already aligned to another initiative for 2022 with which overlap is prohibited; enrolled in FFS Medicare (i.e., not managed care); enrolled in both Medicare Part A and Part B; and residing within the DCE’s Service (Note: CMS has determined that this eligibility check will not be lagged by three months, unlike in PY 2021.) For High Needs Population DCEs, the beneficiary must meet high needs eligibility criteria. The eligibility check pertaining to whether the beneficiary has Medicare as the primary payer will not be included, as data is generally lagged by three months to ensure accuracy.
