WINTER 2021 BOOT CAMP REGISTRATION NOW OPEN! Give your staff a leg up on building and maintaining successful programs in value-based care. Avoid travel cost and time away from the office and home by attending our virtual program January 26 – 27 from 11:00 am – 4:00 pm ET with deep dives into critical issues with small group discussions to ask questions pertaining to your model/track.
Benchmarking and Risk-adjustment
Chronic Care Management Programs
Data Sources and Strategies
Medicare Advantage Contracting
Discussion groups for peers from same track
Register today for this unique opportunity to learn from experts who have successfully transitioned to value-based care.
Pricing:
$595 for individuals from ACO members
ACO member organizations can register up to 15 people people for $2500
$795 for individuals from non-member ACOs
ACO non-members organizations can register up to 15 people for $3500
The boot camp is not open to business partners or other vendor organizations. Attendees must have valid membership status during the boot camp.
CMMI RELEASES INFORMATION ON GEOGRAPHIC DC OPTION The CMS Innovation Center (CMMI) this morning released a Letter of Intent (LOI) for the Direct Contracting (DC) Model’s Geographic Option, the third piece of DC that seeks to make providers responsible for all of fee-for-service (FFS) beneficiaries in an entire region or metropolitan area. Citing concern with provider and beneficiary churn within legacy ACOs and value-based payment models, the Innovation Center wants to improve long-term care management by making organizations accountable for all FFS patients, even those currently assigned to legacy ACOs. Geographic DC Entities would have more options for provider reimbursement and tools for beneficiary engagement.
Non-binding Letters of Intent (LOIs) are due December 21 for organizations in 15 regions. A formal Request for Applications is expected in January 2021 for a narrower list of regions. The option would be tested over a six-year period in four-to-ten regions with two three-year performance periods, starting in 2022. There would be multiple organizations per region to help mitigate competition issues.
NAACOS has held several meetings with CMMI staff on the geographic option and has raised numerous questions and concerns about overlap with legacy ACOs and the chance for beneficiary confusion. We have raised with the agency the notion that testing certain concepts through the geographic option could be done with existing ACO and CMMI programs. More information is available on this factsheet and CMMI page. Please reach out to advocacy@naacos.com with your questions and feedback.
PRESIDENTIAL TRANSITION OFFICIALLY BEGINS After an initial delay, the General Services Administration (GSA) sent a letter to President-Elect Joe Biden and his team last week to formally begin the presidential transition process. In response, the Trump Administration has begun holding COVID-19 briefings with the Biden Transition Team. This week President-Elect Biden also announced members of his economic team: Janet Yellen, Secretary of the Treasury; Neera Tanden, Director of the Office of Management and Budget; Wally Adeyemo, Deputy Secretary of the Treasury; Cecilia Rouse, Chair of the Council of Economic Advisers; and Jared Bernstein and Heather Boushey, members of the Council of Economic Advisers. President-Elect Biden is expected to begin announcing senior health appointments in the coming days. New Mexico Gov. Michelle Lujan Grisham, former Surgeon General Vivek Murthy, and Rhode Island Gov. Gina Raimondo are reported as being the leading candidates to serve as HHS Secretary.
CMS FINAL 2021 MPFS RULE OVERHAULS ACO QUALITY, AMONG OTHER CHANGES This week, CMS released the final 2021 Medicare Physician Fee Schedule (MPFS) Rule. The rule includes updates to Medicare physician payment policies and the Quality Payment Program (QPP) for 2021. Importantly, the rule finalizes significant changes to quality assessments for Medicare Shared Savings Program (MSSP) ACOs starting with Performance Year (PY) 2021.
NAACOS will hold a webinar on December 18 to review these changes for ACOs — register today!
Key issues affecting ACOs include CMS policies to:
Replace the current quality assessment structure and measures by:
Introducing a new Alternative Payment Model [APM] Performance Pathway (APP) that will allow ACOs to choose to report the Web Interface measures for 2021 or the reduced, three electronic clinical quality measures (eCQMs) found in the APP — CMS will require reporting the APP measures starting in 2022,
Providing automatic full credit for Consumer Assessment of Healthcare Providers and Systems (CAHPS) for ACOs measures for 2020, and
Increasing the minimum attainment standard and making changes to the way quality scores contribute to shared savings and loss calculations.
Maintain the current extreme and uncontrollable circumstances policy for quality scores in 2020, therefore ACOs who are unable to report quality data for 2020 due to COVID-19 will be provided with the mean quality score;
Revise the policy for determining the amount of repayment mechanism arrangements for certain renewing and re-entering ACOs;
Add new codes to the definition of primary care services used in the methodology to assign beneficiaries to ACOs;
Decrease the Medicare conversion factor to $32.41, which is a decrease of roughly 10 percent from $36.09 finalized in the 2020 MPFS Rule;
Continue implementation of significantly revising payment and coding for office/outpatient Evaluation and Management (E/M) services;
Revalue code sets that include, rely upon, or are analogous to office/outpatient E/M visits commensurate with the increased values finalized for office/outpatient E/M visits for 2021, and finalize a new code G2212 for prolonged office/outpatient E/M visits with the same valuation as CPT code 99417;
Change the methodology for addressing prospectively aligned beneficiaries for Qualifying APM Participant (QP) score calculations and establish a targeted review process;
Replace the Merit-based Incentive Payment System (MIPS) APM Scoring Standard with a new APM Performance Pathway (APP) for MIPS APMs, including ACOs; and
Permanently add new services to those eligible for telehealth, including those for home health, while making other changes and clarifications to remote patient monitoring.
The CMS factsheet and the QPP factsheet are available. NAACOS staff are currently reviewing the regulation and will provide a more thorough analysis to members and will provide additional educational resources in the weeks to come. Should you have any questions, please email us at advocacy@naacos.com.
HUNDREDS OF ACOS ASK CONGRESS TO FREEZE QP THRESHOLDS Roughly 500 ACOs, medical practices, and health systems joined a letter that was sent to congressional leaders this week asking for Congress to freeze thresholds to receive Medicare’s 5 percent Advanced APM bonus. The thresholds are set to jump to unrealistic levels in 2021. NAACOS joined other trade associations in collecting signatures. More than 160 ACOs joined the letter, and we thank all of you who did. Congress is strongly considering the freeze, and we hope this letter sends a strong message to lawmakers that the issue needs to be addressed. NAACOS also issued a press release. If you’re interested in writing your elected representatives, you can visit our Take Action page to access a draft letter to your members of Congress.
CONGRESS RACING TO FINISH YEAR-END BUSINESS Lawmakers have until December 11 to extend government funding and address expiring health programs. Congressional leaders reached a tentative deal last week on top-line Fiscal Year (FY) 2021 funding levels, clearing the way to begin negotiations on an omnibus spending package. Another short-term funding extension is possible if a bipartisan agreement is not reached in the coming days. There are also a number of Medicare reimbursement issues that are gaining the attention of lawmakers as possible additions to a spending package.
Additionally, after several months of disagreements on a COVID-19 relief package, a bipartisan group of House and Senate lawmakers announced a compromise framework that both Speaker Nancy Pelosi (D-CA) and Senate Democratic Leader Chuck Schumer (D-NY) endorsed as a starting point for negotiations. The bipartisan framework would provide $908 billion in stimulus funds, including $35 billion in provider relief funds and $16 billion for vaccine distribution, coronavirus testing and contact tracing efforts. While Congressional leaders are discussing linking a COVID-19 stimulus proposal with a FY 2021 spending package, it remains unclear if Congress and the White House will be able to reach an agreement on the size and scope of a relief package. NAACOS and our stakeholder partners are strongly advocating for Congress to address increasing QP thresholds in any end-of-year package.
CMS ISSUES FINAL RULE MAKING CHANGES TO PHYSICIAN SELF-REFERRAL LAW On November 20, 2020, CMS issued a final rule to modernize and clarify the regulations that interpret the Medicare physician self-referral law. A CMS fact sheet is available. The rule creates new permanent exceptions for value-based arrangements, provides additional guidance on key requirements of the exceptions to the physician self-referral law, reduces administrative burdens, and establishes protection for non-abusive, beneficial arrangements that apply regardless of whether the parties operate in a fee-for-service or value-based payment system. The regulations will go into effect on January 19, 2021, with the exception of a January 1, 2022 effective date for the special rules for profit shares and productivity bonuses.
CMMI RELEASES DETAILS ON DC’S STOP-LOSS, STATE REGULATORY GUIDANCE CMMI released more guidance regarding the DC Model. One paper walks through stop-loss reinsurance and details of the Financial Guarantee. It also outlines the methodology for calculating gross savings and shared savings as part of the settlement process, including adjustments made for the trend, seasonality, and any applicable discounts and/or withholds. A separate public-facing guidance document tries to answer basic questions about the model and how it interacts with state regulatory requirements. This intends to help DC Entities follow state requirements that may be applicable.
UPCOMING WEBINAR ON MANAGING PAYERS AND NEGOTIATING CONTRACTS Join us on December 9 at 2:00 pm ET for a webinar on a national ACO’s data-driven strategy for managing payers and negotiating contracts. Steward Health Care Network (SCHN) is a clinically-integrated, community-based ACO serving more than 2 million patients in nine states under Commercial, Medicare, and Medicaid contracts. SHCN’s mature data analytics investment has enabled it to effectively negotiate value-based contracts and then drive performance against many types of risk-based payment models. SCHN President John Donlan previously led their payer strategy and managed care risk contracting and oversaw a major national expansion in SHCN’s managed care footprint. Data has been foundational to those efforts. For over a decade, SHCN has partnered with Arcadia to support its data-driven value-based care initiatives, aggregating data from dozens of electronic health record and health plan data sources and harnessing insights within clinical and administrative workflows to drive value-based outcomes. Donlan will explain how his team approaches negotiating better data access from payers and then uses data to support an effective risk management program and drive further payer negotiations using data.
UPCOMING WEBINAR ON DIRECT CONTRACTING Join us on December 17 at 2:00 pm ET to learn more about the Direct Contracting model, a new CMS voluntary payment model, scheduled to start April 1, 2021. The anticipated model builds upon learnings from the Next Generation ACO Model, offers participants increased risk options, and is an integral component of CMMI’s strategy to redesign primary care as a platform to drive reductions in costs. The high-risk model is an opportunity for participants to drive consistent and meaningful revenue, improve patient outcomes, and lower global utilization and costs. As participants prepare for success within Direct Contracting, it is important to evaluate care coordination strategies and resources. Real-time admission, discharge, and transfer (ADT) data and insights will be a critical tool for success and will support proactive patient engagement and care interventions.
Join our webinar to learn about:
An overview of the Direct Contracting Model
Top considerations participants should review to prepare for the start of the model on April 1, 2021
How to leverage real-time notifications and insights to increase patient engagement and reduce utilization costs
CALL FOR SUBMISSIONS FOR NAACOS LEADERS IN QUALITY EXCELLENCE AWARDS The NAACOS Leaders in Quality Excellence awards have been established to recognize the outstanding efforts among ACOs working to improve the quality and safety of patient care and advance population health goals. At this time, we are inviting NAACOS ACO member organizations to submit an entry for a quality project recently taken on by the ACO to improve the quality of care provided to its patients. NAACOS will recognize the top three submissions, selected by the NAACOS Quality Committee at our Spring 2021 Conference, to showcase the exemplary efforts in quality improvement among our members and to disseminate best practices. NAACOS invites ACOs to submit projects that demonstrate innovative quality improvement strategies to improve patient health outcomes. Examples of projects could include initiatives implemented as part of the ACO’s COVID-19 response, programs that address disparities in health outcomes, or other innovative quality improvement strategies used by your ACO to improve patient health outcomes. To be considered, entries must be submitted by January 31, 2021. Please limit entries to one submission per ACO. More information on the award criteria and submissions process are available. Should you have any questions, please contact us at advocacy@naacos.com.
TRUMP ADMINISTRATION ANNOUNCES PRESCRIPTION DRUG PAYMENT MODEL CMS in late November announced a mandatory, nationwide CMMI model that will tie Medicare Part B drug prices to those that other countries pay. Scheduled to start on January 1, the Most Favored Nation Model would pay the lowest Gross Domestic Product (GDP)-adjusted price for a drug paid by certain OECD countries. The current add-on payment would be replaced with a flat payment uniform for all drugs in the model. Overall, the model is scheduled to last for seven years and would initially focus on 50 high-cost Part B drugs. The model would be mandatory for all Medicare providers and suppliers starting in January, except for cancer hospitals, children’s hospitals, critical access hospitals, rural health clinics, federally qualified health centers, and Indian Health Service facilities.
While ACOs often struggle with the high costs of Part B drugs, the drug industry has already vowed to stop the Most Favored Nation Model’s implementation. Therefore, it’s unclear what the program’s future will be. Late in 2018, NAACOS submitted comments on a similar, but different, proposed model to tie Medicare Part B drug prices to international prices. More information on the Most Favored Nation Model is included on CMMI’s site, including an interim final rule with comment, fact sheet, and other supporting documentation.
HHS ISSUES REQUEST FOR INFORMATION ON COVID-19 RESPONSE BEST PRACTICES HHS has opened a Request for Information regarding best practices in COVID-19 response among the health care community. As ACOs and healthcare systems innovate to respond to this pandemic, HHS plans to identify and learn from effective, innovative approaches and best practices in order to inform HHS priorities and programs. Submit your response to this Request for Information by December 5, 2020. More information is available in the Federal Register post.
PRIMARY CARE FIRST PARTICIPANTS ANNOUNCED CMMI recently announced the first cohort of participants in the new Primary Care First (PCF) Model. The 916 primary care practice participants will begin the new PCF Model on January 1, 2021. Additionally, CMMI notes 37 regional partnerships with commercial, state and Medicare Advantage plans will be partnering across the selected PCF regions with participants. The PCF model is a voluntary model aimed at rewarding value by providing innovative payment structures to support the delivery of advanced primary care services. Learn more about the model on the PCF page.
CMS EXTENDS DEADLINE FOR ADVANCED APM BONUS PAYMENT TO DECEMBER 13 As a result of NAACOS advocacy, CMS has extended the deadline to request the 5 percent Advanced APM bonus for those clinicians who were not paid due to missing billing information. In order to receive the payment, these clinicians will need to verify their Medicare billing information by December 13, 2020. If you have already received your 5 percent bonus payment, you do not need to take any action. If clinicians have not received payment and find their name on this public notice, they must verify their Medicare billing information by the new deadline to receive payment. For more information, review the QP Public Notice File for Payment Year 2020 Excel Spreadsheet and supporting forms in the 2020 QP Notice for APM Incentive Payment files. The spreadsheet will indicate which form you need to submit—the IP Form and/or 588 Form — in order to verify your Medicare billing information.
CMS TAKES STEPS TO ENHANCE HOSPITAL CAPACITY AMID COVID-19 SURGE CMS recently announced new flexibilities to combat a surge in COVID-19 cases, providing new allowances for hospital care for eligible patients in their homes and updating staffing flexibility designed to allow ambulatory surgical centers (ASCs) to provide greater inpatient care when needed. More information on the ASC flexibilities is available.
The Acute Hospital Care At Home Program expands on the Hospital Without Walls program authorized in March. The new program provides eligible hospitals with new regulatory flexibilities to treat eligible patients in their homes in order to assist facilities with a surge of COVID-19 patients. Acute Hospital Care at Home is for beneficiaries who require acute inpatient admission to a hospital and who require at least daily rounding by a physician and a medical team monitoring their care needs on an ongoing basis. CMS launched an portal to streamline the waiver request process and allow hospitals and healthcare systems to submit the necessary information to ensure they meet the program’s criteria to participate.
CMS TO HOLD TOWN HALL JANUARY 7 ON MIPS VALUE PATHWAYS APPROACH CMS will hold a virtual Town Hall discussion on January 7, 2021 from 9am to 4pm Eastern to discuss the future of the Merit-Based Incentive Payment System (MIPS) and in particular, the new MIPS Value Pathways (MVP) approach the agency expects to roll out in the coming years to streamline reporting requirements and ease burdens for providers subject to MIPS. To attend the virtual session, you must register for the event in advance.
