NAACOS Newsletter for Members and Partners December 17 2020
| WINTER 2021 BOOT CAMP AGENDA RELEASED NAACOS’ upcoming Winter Boot Camp will give your staff a leg up on building and maintaining successful programs in value-based care. Since our program is virtual January 26–27 from 11:00 am to 4:00 pm ET, you and your staff will be able to avoid travel cost and time away from the office and home!! Sponsored by Milliman and Salient, our program contains deep dives into critical issues and small group discussions to ask questions pertaining to your model/track. The full agenda is now available. Register today for this unique opportunity to learn from experts who have successfully transitioned to value-based care. ACO members can register for $595 for an individual or $2,500 for up to 15 people in an organization. Non-members can register for $795. There is no organizational rate for non-member ACOs. The boot camp is not open to business partners or other vendor organizations. MPFS RULE ANALYSIS AND WEBINAR FOR NAACOS MEMBERS The final 2021 Medicare Physician Fee Schedule (MPFS) Rule was released on December 1, 2020. Given the late release of this rule, many ACOs are seeking resources and education on the provisions in the rule affecting ACOs. NAACOS has developed an in-depth analysis of the rule, highlighting key changes for ACOs taking effect in 2021. Additionally, NAACOS staff will host a webinar on December 18 from 2:00 to 3:15 pm ET to provide an overview of the rule and key changes for ACOs looking to implement these policies in 2021. Register today! |
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| NAACOS LETTER TO CMS ASKS FOR DIRECT CONTRACTING CHANGES NAACOS is urging the CMS Innovation Center in a letter to correct the Direct Contracting Model, which may disenfranchise legacy ACOs under current rules. We fear the way the Innovation Center calculates benchmarks will be unfair to ACOs who have spent several years lowering the cost of care on their patient populations. Furthermore, the discounts are too steep and risk adjustment policies for High Needs Population entities should apply to all high-needs patients in all Direct Contracting Entity (DCE) types, not just High Needs. Lastly, NAACOS expressed grave concern around the recently announced Geographic Option for Direct Contracting. This Option, which would have a DCE take accountability for randomly assigned Traditional Medicare patients in a geographic region, should be stopped while the incoming administration evaluates its impact. Instead, NAACOS recommends that certain policy goals of the Geographic Option would be better tested in Direct Contracting’s Professional and Global Options and/or other ACO programs. NAACOS RESOURCES ON NEW FINAL STARK LAW RULES On November 20, 2020, CMS and the Department of Health and Human Services (HHS) Office of Inspector General (OIG) finalized rules creating new exceptions to the Federal Physician Self-Referral or “Stark Law” and safe harbors under the Federal Anti-Kickback Statute. NAACOS has a Top Takeaways resource for ACOs available. NAACOS’ policy team and attorneys from Polsinelli PC will also be hosting a webinar on Monday, December 21 at 2:00 pm ET to provide an overview the new flexibilities, definitions, and safe harbors/ exemptions for value-based arrangements. Register Now! CONGRESS RUSHING TO ADDRESS UNFINISHED BUSINESS Lawmakers have until Friday, December 18, to extend government funding and address expiring health programs. Congressional leaders are working around the clock on final details of a $900 billion COVID-19 stimulus bill that is expected to be attached to a fiscal 2021 omnibus spending package. Lawmakers are also pushing to include provisions that address expiring health programs, Medicare payment cuts, QP thresholds, and surprise medical billing. NAACOS and our stakeholder partners are strongly advocating for Congress to include a provision in the year-end package that will keep QP thresholds from increasing in 2021. The final year-end packages are expected to be introduced as soon as an agreement is reached. Congressional leaders have committed to passing a year-end package, but short-term funding extension is possible if additional time is needed for final passage. 2020 ACO QUALITY REPORTING TO BEGIN IN JANUARY 2021 The ACO quality submission period for the 2020 performance year will open on January 4, 2021. At that time, ACOs may begin submitting quality data to CMS for the 2020 performance period. The submission period will close on March 31, 2021. Please note that CMS has an extreme and uncontrollable circumstances policy which will provide ACOs with the 2020 ACO mean quality score if they are unable to report quality data due to extreme and uncontrollable circumstance, such as the COVID-19 Public Health Emergency. Additionally, in the final 2021 MPFS rule CMS notes ACOs who are able to report quality data will be given the higher of their 2020 quality score or the mean quality score for the 2020 performance year. Do you feel you will be unable to report quality data for the 2020 performance year due to COVID-19? If so, please let us know by emailing advocacy@naacos.com and including ‘Quality reporting problems’ in the subject of your email. NAACOS WRITES CMS ON IMPLEMENTATION OF ADT-SHARING REQUIREMENT In a recent letter to CMS, NAACOS asked that the agency act quickly to correct implementation issues surrounding its Interoperability and Patient Access Final Rule that requires hospitals to share electronic notifications of patients’ admission to, discharge from, or transfer between inpatient hospitals. Specifically, NAACOS asked that CMS clarify the statement that the condition of participation (CoP) “does not create an entitlement for any specific provider or intermediary to receive patient event notifications,” which includes ACOs. We also asked that CMS allow ACOs to give rosters of ACOs’ assigned beneficiaries as acceptable lists for whom hospitals must share admission, discharge, and transfer (ADT) notifications. CMS said on a recent call that it plans to release sub-regulatory guidance around ADT sharing this spring. Given the importance of ACOs’ access to critical patient data, NAACOS plans to follow this issue closely to ensure it’s addressed before the requirement takes effect on May 1, 2021. NAACOS members can access this resources that explains that ADT rule and other “information blocking” rules finalized earlier this summer.  DIRECT CONTRACTING DEADLINES Letters of Intent to participate in the Geographic Direct Contracting Model are due Monday, December 21. The letters are non-binding and don’t require an organization to submit an application. December 21 is the deadline for DCEs participating in the model’s implementation period to send their beneficiary notification letters. Also, lists of patients who have signed up for voluntary alignment through paper are due to CMS. DCEs should start to receive notices about their benefit enhancement and payment selections starting next week. For more information and resources on Direct Contracting, visit the NAACOS dedicated, stand-alone Direct Contracting page. OPEN CALL FOR 2021 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 to 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 used by your ACO 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. MIPS HARDSHIP EXCEPTION DEADLINES APPROACH CMS is allowing Alternative Payment (APM) Entities, including ACOs, the ability to request a Merit-based Incentive Payment System (MIPS) hardship exception for full reweighting of all categories in order to receive a neutral MIPS score for 2020. Once a hardship application is requested, if awarded, it will override any data submitted by the ACO or its participants. ACOs will be required to attest that at least 75 percent of participant MIPS eligible clinicians (ECs) would be eligible for reweighting the Promoting Interoperability (PI) performance category for the applicable performance period to be eligible for this full reweighting (neutral MIPS score). Hardship exceptions are due by February 1, 2021, for PY 2020, and determinations apply to all clinicians in the ACO; applications can be submitted via the Quality Payment Program (QPP) website. Alternatively, individual ECs and group/TINs may want to submit a hardship exception for the PI category specifically, which is due December 31, 2020 — this cannot be done by the ACO and instead must be done by each clinician or group/TIN. Using this option removes the clinician or group from the denominator of the average ACO PI score and allows the ACO and its clinicians to continue to be eligible for possible bonuses or penalties in MIPS. The PI hardship exception should be submitted through the QPP website. |
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| HIPAA PROPOSED RULE RELEASED HHS’s Office for Civil Rights issued a proposed rule that, if finalized, would change privacy rules around the Health Insurance Portability and Accountability Act (HIPAA) to make it easier to coordinate care and improve patient access to their medical information. Among the various changes, the proposed rule would allow HIPAA covered entities to share patient information with social services agencies, community-based organizations, and other health-related parties for individual care management in a move that may make it easier to address social determinants of health. NAACOS submitted comments early last year in response to a request for information on possible HIPAA changes. With the pending administration change, it’s unclear if any of these proposed changes will be finalized, but NAACOS will watch and likely comment on the proposed rule regardless. RADIATION ONCOLOGY MODEL DELAYED The CMS Innovation Center will delay its Radiation Oncology Model by six months for a July 1, 2021 start date. The change, although originally announced by CMS in October, was formalized through rulemaking in the recent 2021 Hospital Outpatient Prospective Payment Final Rule. The model will test bundled, prospective, episode-based payments for radiation treatment for 16 cancer types. The model will run through 2025, as originally scheduled. MSSP ASSIGNMENT REPORTS DELIVERED; CHANGES TO ENHANCED REPORTS CMS recently delivered 2021 assignment reports to Medicare Shared Savings Program (MSSP) ACOs, including ACOs’ Assignment List Reports (ALRs) and Assignment Summary Reports (ASR), which are accessible via the ACO-MS Data Hub and an ACO’s Managed File Transfer mailbox, as well as through the SSP ACO Portal. In the reports, CMS is denoting those beneficiaries assigned via claims and those who have voluntarily aligned. The agency is also introducing the Long-Term Institutionalized Status measure in the ASR. It’s important to note that with the retirement of the SSP ACO Portal, CMS will no longer provide ACOs with Enhanced Reports. NAACOS expressed concern with this, and the agency explained that ACOs may use data in the ASRs and ALRs to create their own reports. CMS is exploring options to replace the data currently provided through the Expenditure/Utilization drill down enhanced report, which provides beneficiary-level expenditure and utilization data, with a CSV file in the upcoming Informational Report packages beginning in PY 2020 Quarter 4 reports. |
