NAACOS Newsletter for Members and Partners December 30, 2021

Table of Contents

NAACOS ADVOCACY

Celebrate Medicare’s Anniversary with NAACOS
NAACOS Launches Monthly Government Relations Advocacy Calls
PAC Prior Approval Reminder
NAACOS Recommends Primary Care Capitation in MSSP
NAACOS Joins CMS for Listening Session on APM Bonus
NAACOS Participates in Congressional Roundtable on Medicare Payment
NAACOS Submits Feedback to LAN at Town Hall
New NAACOS Member Resources Available

CONGRESSIONAL UPDATES

Countdown to August Recess

ADMINISTRATION UPDATES

CMS Releases Proposed 2023 Hospital OPPS Rule
COVID-19 PHE Extended into October
New CMS Resources
Important Deadlines Ahead
CMS Webinar on eCQMs on August 3

WHAT WE’RE WATCHING

MedPAC Releases 2022 Data Book

EDUCATION OPPORTUNITIES

CMS Top Officials Confirmed for Fall Conference
What’s Coming in the Next Learning Lab
Two More Affinity Group Meetings To Be Held This Summer
NAACOS Webinar on Mechanics of MSSP Repayment Mechanism
Cerner-Sponsored Webinar on Journey to Value

NAACOS Advocacy

CELEBRATE MEDICARE’S ANNIVERSARY WITH NAACOS
This Saturday, July 30, marks the 57th anniversary of Medicare. Join NAACOS social media campaign to celebrate the program and highlight the importance of accountable care in Medicare’s future. We are encouraging our members to showcase that ACOs save money while delivering high-quality care to beneficiaries. You can participate by using our social media toolkit to share key messages and graphics (a version is available to download and adapt messages to your own success stories) and by visiting Take Action to write to your representatives in favor of policies that support ACOs. Additionally, About ACOs now includes video clips of providers reflecting on the value of ACOs for patients, providers, and our health system. Share these videos or your own success stories to celebrate this #MedicareAnniversary with us!
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NAACOS LAUNCHES MONTHLY GOVERNMENT RELATIONS ADVOCACY CALLS
Throughout the remainder of the year, we are focused on advancing the Value Act and getting Congress to extend the advanced alternative payment model (APM) incentive payments. To ensure that we are staying closely aligned with your government relations teams, the NAACOS government affairs team will be holding monthly calls for your in-house or contracted government relations teams. These calls will be informal forums for sharing updates on congressional outreach and materials that can be used in congressional meetings. The calls are schedule for 2:00 pm ET on the third Thursday of each month. The next call is scheduled for Thursday, August 18. Contact Aisha Pittman or Robert Daley to have your organization’s in-house or external government relations team join.

PAC PRIOR APPROVAL REMINDER
Help us build our Action Fund to support congressional candidates who understand the interests of NAACOS members and value-based care providers. To comply with federal election rules, NAACOS members must provide the NAACOS Action Fund with prior approval before solicitations for funds can occur. Signing the approval does not obligate you or your organization’s leadership to contribute. If you are your organization’s primary contact with NAACOS, we encourage you to review our frequently asked questions and electronically sign the prior approval form.

NAACOS RECOMMENDS PRIMARY CARE CAPITATION IN MSSP
NAACOS president and CEO Clif Gaus; Ann Greiner, president and CEO of the Primary Care Collaborative; and Hoangmai (Mai) Pham, president of the Institute for Exceptional Care, co-authored a blog in Health Affairs Forefront recommending that CMS offer primary care capitation within the Medicare Shared Savings Program (MSSP) as a strategy for advancing accountable care. This was in response to CMS leadership’s New England Journal of Medicine Perspective that outlined the administration’s vision for accountable care. NAACOS continues to engage with primary care leaders to drive health care payment and delivery reform and further our path on the transition to value.

NAACOS JOINS CMS FOR LISTENING SESSION ON APM BONUS
NAACOS Senior Vice President of Government Affairs, Aisha Pittman, was a panelist at a CMS-led listening session on the advanced APM incentives. Panelists agreed that the 5 percent advanced APM incentive payment has been crucial to providers and that the absence of incentives could slow APM adoption. NAACOS and the American Medical Association (AMA) also used the forum to call on CMS to support stakeholder efforts asking Congress to provide a six-year extension of the advanced APM bonus.


NAACOS PARTICIPATES IN CONGRESSIONAL ROUNDTABLE ON MEDICARE PAYMENT
NAACOS and other leading provider organizations participated in a roundtable on Capitol Hill to discuss physician payment reform and incentives to promote value-based care. NAACOS used the opportunity to highlight the work ACOs are doing around the country and called on Congress to extend the 5 percent advanced APM bonus. We urge members to continue contacting your member of Congress and ask them to support these important programs for ACOs.

NAACOS SUBMITS FEEDBACK TO LAN AT TOWN HALL
NAACOS sent feedback to the Health Care Payment Learning & Action Network (LAN) on its new definition of accountable care. The LAN is a public and private multi-stakeholder leadership focused on building multistakeholder consensus for advancing value-based care. NAACOS expressed concerns that the proposed definition deviates considerably from existing definitions used by CMS and others, uses language that may not be accessible to a broad public audience, and does not meaningfully define accountable care. NAACOS will continue to engage the LAN and CMS leadership on alignment of terms for accountable care that are meaningful to consumers.

NEW NAACOS MEMBER RESOURCES AVAILABLE
  • Analysis of the Medicare Physician Fee Schedule (MPFS) proposed rule is now available. The government affairs team is seeking your input on the proposals. Please send to advocacy@naacos.com. Comments are due September 6, 2022. We will make a draft comment letter available ahead of the deadline.
  • Watch on-demand webinars reviewing the MPFS proposed rule. The first webinar provides a 90-minute overview of the proposed rule. The second webinar on the afternoon of July 28th is a deep dive into the financial methodology with presentations by CMS’ Dr. Doug Jacobs, Validate Health’s Andrew Webster, and Aledade’s Travis Broome. A recording will be available after the webinar.
  • A new summary on the Enhancing Oncology Model (EOM) is now available. EOM is a total cost of care model that builds on the lessons learned in the Oncology Care Model (OCM). New elements include an emphasis on health equity, like electronic patient reported outcomes (ePROs), and lower enhanced oncology services payments. Applications are due on September 30 with decisions expected later this year.
Congressional Updates

COUNTDOWN TO AUGUST RECESS
Congress is in session this week to advance several legislative items prior to the August recess. Senate Democrats reached agreement on a budget reconciliation bill, the Inflation Act of 2022. The health provisions of the bill include extension of the Affordable Care Act subsidies and allowing Medicare to negotiate drug prices and cap out-of-pocket expenses. The Senate is expected to vote on the bill next week. Additionally, the Senate will hold a vote on the “CHIPS-Plus” bill, which includes funding for the National Science Foundation and US tech research.

The House passed a telehealth bill sponsored by Rep. Liz Cheney (H.R. 4040) that would extend through 2024 some Medicare payment rules that were allowed during the COVID-19 public health emergency (PHE). This includes waiver of originating site requirements, audio-only telehealth, and an expanded list of telehealth practitioners. The legislation now heads to the Senate. The House Ways and Means Committee held a markup this week in which it advanced Rep. Suzan DelBene’s (D-WA) bipartisan bill to reform the Medicare Advantage prior authorization process.

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Administration Updates

CMS RELEASES PROPOSED 2023 HOSPITAL OPPS RULE
CMS recently released the proposed 2023 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment Systems rule. In this proposed rule, CMS:
  • Increases OPPS and ASC payments by 2.7 percent,
  • Establishes provider enrollment procedures and payment rates for rural emergency hospitals, and
  • Continues payment for remote behavioral health services provided by hospital outpatient departments after the conclusion of the PHE.
While the proposed rule continues CMS’ 340B drug payment policy, the agency expects to make changes in the final rule to comply with the Supreme Court’s recent decision that will require the agency to pay for 340B drugs at average sale price (ASP) plus 6 percent. More information is available in the CMS Fact Sheet. Comments on the proposed rule are due by September 13.

COVID-19 PHE EXTENDED INTO OCTOBER
As NAACOS anticipated, HHS Secretary Becerra renewed the COVID-19 PHE for an additional 90 days on July 15. The PHE will now continue through October 13. Several Medicare policies are tied to the PHE, such as waiving shared losses for MSSP ACOs, removing COVID-19 treatment episodes from performance year expenditures, and broad application of telehealth and three-day skilled nursing facility waivers. HHS has promised a 60-day notice before terminating the PHE. Visit our COVID-19 and ACOs page for more information and contact advocacy@naacos.com with any questions.

NEW CMS RESOURCES
  • The CMS Innovation Center released a synthesis and summary of evaluation results of 21 models. The report found 14 of the 21 generated gross savings to Medicare, including the ACO Investment Model (AIM), Next Generation ACO Model, Pioneer ACO Model, and Vermont All-Payer ACO Model. Six of those proved to generate net savings to Medicare, including AIM and Pioneer. This is outlook much better than an earlier reports which indicated only five models generated savings.
  • ACO REACH health equity plan details were released. The preliminary plans are questions about data sources used to identify underserved populations, the subpopulations within your aligned beneficiaries, and which populations you seek to target. Optional preliminary health equity plans are due September 16. A template for mandatory plans will be released later and will be due in March 2023.
IMPORTANT DEADLINES AHEAD
  • Participant List Changes. For 2023 MSSP and ACO REACH, August 4th is the deadline to add providers, September 9th is the deadline to remove providers.
  • Election to Remain in Level A/B of the MSSP Basic Track. MSSP ACOs currently in Basic Track Levels A/B for performance year 2022 can elect to remain in the Basic Track for the remainder of the agreement period. The deadline to make this election is September 9 at 12pm ET. Note, this is a policy proposed in the CY 2023 MPFS proposed rule. IF CMS does not finalize this policy, the ACO will have limited time to submit a repayment mechanism prior to the start of PY 2023.

CMS WEBINAR ON ECQMS ON AUGUST 3
CMS is hosting an ACO-focused webinar on August 3 at 3:00 pm ET to discuss strategies for electronic clinical quality measures (eCQM)/Merit-based Incentive Payment System (MIPS) CQM quality reporting. ACOs will share their experiences reporting eCQMs for Performance Year 2021 and discuss how they overcame challenges in the process. CMS notes attendees will have an opportunity to ask questions. We encourage members to ask questions related to the challenges you are facing regarding the transition to eCQMs. Background information can be found in our resource. Additionally, we are hosting an eCQM-focused workshop and round table discussion at our upcoming fall conference.

What We’re Watching

MEDPAC RELEASES 2022 DATA BOOK
The Medicare Payment Advisory Commission (MedPAC) released its 2022 Data Book, which provides information on national health care and Medicare spending. The report includes information on APMs and ACOs in Section 5. Highlights of the databook include:
  • 72 percent of Medicare beneficiaries are in a managed care relationship through either MA or an ACO.
  • The number of beneficiaries assigned to MSSP ACOs grew rapidly through 2018 but has leveled off in recent years.
  • On average, 24 percent of clinicians participating in an MSSP ACO are primary care physicians, while 46 percent are specialists, and 30 percent are nonphysician providers.

NAACOS Education Opportunities

CMS TOP OFFICIALS CONFIRMED FOR FALL CONFERENCE
Join us September 7–9, 2022, for the NAACOS Fall Conference at the Marriott Marquis in Washington D.C. The agenda will feature leading ACO experts and CMS officials sharing timely and essential information for ACOs. 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.

Chiquita Brooks-LaSure, the Administrator for the Centers for Medicare and Medicaid Services (CMS), is confirmed to keynote day one of the conference. Liz Fowler, CMMI Director, will open day two of the conference. The full agenda is available.

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 be focused on:
  • ACO REACH Compliance and Waivers chaired by Beth Patak, Equality Health
  • Preparing for eCQM Reporting chaired by Anna Taylor, MultiCare Connected Care
Hotel discounted rate ends August 1 for the Marriott Marquis. All reservations must be made by August 1 to qualify for the discounted room rate of $289 a night, single or double occupancy per night plus 14.95 percent sales tax (based upon availability).

Exhibitor and Sponsor opportunities are still available! The NAACOS Fall Conference will feature exhibitors with products and services specifically for the accountable care community. Reserve your space today!

WHAT’S COMING IN THE NEXT LEARNING LAB
Do you have an interest in learning more about Medicaid ACOs? Then we have the Learning Lab for you! Come a day early to the fall conference and join our Medicaid Learning Lab workshop on September 7 from 1:00 to 5:00 pm ET. Register today for this in-person session focusing on the needs of ACOs working within the Medicaid space. Topics will include clinical and operational issues unique to Medicaid populations and their geographic challenges. This event, which is separate from the conference, is free to current NAACOS ACO members. Because there is no fee to register, we are limiting participation to one person per organization for the in-person session. Additional staff may participate in follow up Lab activities held virtually.

Those participating in the ongoing Specialist Engagement and Incentives Learning Lab will also meet at this time. Those registered for that Lab will receive additional information on session continent in coordination with your monthly group meetings.

If a representative from your ACO has expertise to present or would like to take a more active role in a learning labs, please reach out to Melody Danko-Holsomback, VP of Education, mdholsomback@naacos.com.


TWO MORE AFFINITY GROUP MEETINGS TO BE HELD THIS SUMMER
Virtual meetings for three of our new affinity groups have been a great success and offered the opportunity for robust peer-to-peer conversations. Don’t miss your chance to join executive and clinical peers in the final two summer Affinity Group meetings. These sessions will focus on the hot topics in population health that are essential to the work you do every day.

Sign up today to join the Executive Affinity Group on August 3 from 2:00 to 3:00 pm ET or the Clinical Affinity Group on August 10 from 3:00 to 4:00 pm ET. *Note the time for the Executive Group has changed due to a conflict with a recently announced CMS webinar on eCQM.

Sign up is for the series and you will need to add the dates and Zoom links to your calendars. Additional session dates and times will be included when you sign up for the series. In addition, join us for the in-person Affinity Group exchanges at the NAACOS Fall Conference on September 8 in Washington, D.C.

UPCOMING NAACOS WEBINAR ON MECHANICS OF MSSP REPAYMENT MECHANISM
On August 15 from 3:00 to 4:00 pm ET, join Stephen Nuckolls, Coastal Carolina Quality Care, and Jill Watson, Centrus Health, as they help explain the mechanics of the MSSP repayment mechanism. This webinar will provide the basic information you need to understand the choices for the MSSP repayment mechanism. We will include information on each of the options, why you many chose one method over another, and how to obtain and submit the needed documentation. We will also review the calculations CMS uses to determine the required amounts so that you can estimate the amount for your ACO. The webinar is free to members and business partners and $195 for non-members. Register Now!

CERNER-SPONSORED WEBINAR ON JOURNEY TO VALUE
Between the pressures of escalating costs, an aging population, healthcare delivery disruption and increased regulatory demands, many are feeling the weight of an unsustainable healthcare system. So how are you juggling today’s healthcare demands? One health system turned to value-based care strategies.

On August 10 from 2:00 to 3:00 pm ET, hear Patrick Young, president of population health from Hackensack Meridian Health (HMH), the largest health system in New Jersey, discuss HMH’s choice to transform its healthcare delivery. Patrick will share his insight into HMH’s ongoing value-based care journey, how they are connecting their healthcare ecosystem, value-based care strategies that have improved health care for their population and enhanced financial sustainability, and essential components to diversify from fee-for-service to a value-based delivery model. Sponsored by Cerner, registration for this webinar is complimentary for NAACOS ACO members. Register Now!