HAPPY NEW YEAR TO OUR MEMBERS AND PARTNERS! 2020 has been an incredibly challenging year across the globe. NAACOS members understand this better than most, as they have been on the front lines throughout this devastating pandemic. One silver lining is our physicians, nurses, hospitals, and medical professionals, who continue to put patients first. What also inspires us at NAACOS is how our members and partners came together to support one another clinically and operationally. As we saw a greater need for virtual learning and sharing of best practices, NAACOS was proud to facilitate these exchanges among members and the broader ACO community. On behalf of the NAACOS board and staff, we wish you all a very Happy New Year. We look forward to continuing our work with you to advance value-based care initiatives.
NAACOS AND ACO ADVOCACY SECURES TWO-YEAR QP THRESHOLD FREEZE Following intense advocacy from NAACOS, ACOs and other stakeholders, Congress included a provision in the year-end spending and COVID-relief bill to encourage continued participation in Advanced Alternative Payment Models (APMs), including many ACO models. The bill, which was signed by President Trump this week, freezes the payment amount and patient count Qualifying APM Participant (QP) thresholds at 2020 levels for 2021 and 2022. ACOs must meet these thresholds to secure a 5 percent bonus on annual Medicare payments.
Freezing the QP thresholds was a top advocacy priority for NAACOS this year, and advocacy efforts ramped up in the latter half of the year, including many meetings, grassroots activities, and other efforts, such as:
Working to convene more than 500 ACOs, medical practices, and health systems urging congressional leaders in a letter to address the payment thresholds;
Sending a similar letter in November from NAACOS and 18 other leading healthcare associations;
Advocating for lawmakers to write Speaker Nancy Pelosi (D-Calif.) and Minority Leader Kevin McCarthy (R-Calif.) asking the House to address the incentives; and
Conducting a survey showing the positive effects of the bonuses and the difficulty ACOs face with the higher thresholds.
We are thankful that congressional leaders responded to these advocacy efforts and look forward to working with our congressional champions on other ACO priorities in 2021!
NAACOS SUMMARIZES KEY CHANGES IN YEAR-END BILL FROM CONGRESS To help NAACOS members better understand the changes Congress enacted in the recent omnibus spending and COVID-19 relief bill, NAACOS created a new resource to highlight key provisions. The new law has several ramifications for healthcare providers in addition to freezing QP thresholds at 2020 levels for the next two years, which as noted above was a top NAACOS priority for 2020. The bill addresses scheduled cuts to Medicare evaluation/management payments, tries to stop out-of-network, surprise medical billing, improves price transparency, and also provides additional funding for pandemic relief.
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.
NAACOS MEMBER DUES INCREASE NAACOS is instituting a small increase to membership dues effective January 1, 2021, for ACO members with fewer than 25,000 beneficiaries. This is the first dues increase for this membership segment since NAACOS’ inception in 2013. Pricing can be found on our membership page.
2020 ACO QUALITY REPORTING BEGINS JANUARY 4 The ACO quality submission period for Performance Year (PY) 2020 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. CMS delivered a Web Interface Patient Sample Excel file to each ACO on December 18, 2020. This file contains the same patient sample that will be available through the Web Interface beginning on January 4. CMS provides the sample in advance to allow ACOs to begin locating patient records they will need for quality reporting. The reports will be available through the Manage File Transfer (MFT) and ACO-MS Data Hub (reports section) through December 31, 2020. CMS will begin hosting Web Interface support webinars beginning January 27, 2021, from 1–2:30 pm ET; more information including registration details are provided in the ACO Spotlight Newsletters circulated to all ACOs. Finally, Medicare Shared Savings Program (MSSP) quality measure benchmarks for PY 2020 are now available on the CMS MSSP Guidance and Specifications webpage (refer to Quality Resources section). These documents have been updated on December 23, 2020, to reflect benchmark changes due to the removal of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for ACOs survey requirement for 2020.
As a reminder, CMS has an extreme and uncontrollable circumstances policy that will provide ACOs with the 2020 ACO mean quality score if they are unable to report quality data due to extreme and uncontrollable circumstances, such as the COVID-19 Public Health Emergency. Additionally, in the final 2021 Medicare Physician Fee Schedule (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 PY 2020.
UPDATED NAACOS ANALYSIS OF FINAL 2021 MPFS RULE NAACOS has developed an in-depth analysis of the final 2021 MPFS Rule, highlighting key changes for ACOs taking effect in 2021. NAACOS recently updated this analysis to include clarifications from CMS regarding ACO quality assessment changes as well as updates made by subsequent legislation recently passed by Congress. Additionally, NAACOS staff hosted a webinar, available on-demand, to provide an overview of the rule and key changes for ACOs looking to implement these policies in 2021.
NEW ON-DEMAND WEBINARS: FINAL 2021 MPFS AND STARK RULES Following the release of key regulations in late November and December, NAACOS hosted two webinars, which are now available on-demand. These webinars walk through the complex Medicare regulations and point out key information for ACOs:
Reviewing Changes to the Stark Law and Federal Anti-Kickback Statute. The slides and recording are available now! NAACOS also recently released a resource outlining key takeaways from these regulatory changes.
Final 2021 MPFS Rule: Key Changes for ACOs. As noted in the article above, the NAACOS webinar walking through the final 2021 MPFS Rule is also available with slides and a recording.
There are also a variety of other on-demand webinars from the last quarter of 2020 focusing on important and timely topics including the Direct Contracting Model, managing payers and contracts, post-election recap, building blocks for compliance across Medicare APMs, and more.
Welcome New ACO Member
Caravan Health ACO 16 Huntsville, AL
QPP PARTICIPATION STATUS TOOL NOW INCLUDES THIRD 2020 SNAPSHOT The Quality Payment Program (QPP) Participation Status Tool has been updated to include third snapshot data for 2020. Visit the Participation Status Tool to review your 2020 eligibility status which has been updated to include data from January 1 to August 31, 2020, for identifying QP status and Merit-Based Incentive Payment System (MIPS) APM participation status. QP or MIPS APM status can be viewed at the individual (NPI) or APM entity (ACO) level. As a reminder, the QP status threshold is 50 percent in 2020 while the patient count threshold is 35 percent. More information on QP thresholds is available in the NAACOS ACO Guide to MACRA.
JANUARY 31 DEADLINE TO NOMINATE LEADERS IN QUALITY EXCELLENCE 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 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 is available. Should you have any questions, please contact us at advocacy@naacos.com.
DEADLINE APPROACHING ON BENEFIT ENHANCEMENTS FOR DIRECT CONTRACTING The window for Direct Contracting Entities (DCEs) participating in PY 2021 to elect benefit enhancements and payment mechanism is now open and will close on January 14. CMS reminds participants that DCE-level elections (such as which enhancements will be offered) must be made before individual elections are made (such as which preferred providers will participate in such enhancements). The agency also notes that the hospice benefit is only available to Global DCEs. CMS is hosting webinars on January 5 and January 12 on benefit enhancements and payment mechanism elections. Visit NAACOS’s Direct Contracting page for more resources and guidance.
Related to Direct Contracting, CMS announced earlier this month an opportunity for Medicaid Managed Care Organizations (MCOs) to participate in Direct Contracting starting in January 2022. CMS aims to better serve beneficiaries dually eligible for Medicare and Medicaid. The agency expects to release a request for applications for all Professional and Global DCE types, including MCO-based DCEs early next year.
ACO PUBLIC REPORTING DUE JANUARY 22 ACOs participating in MSSP must update their public reporting webpage annually. All ACOs must update their public reporting page with PY 2021 information by January 22, 2021, if changes to your organization occurred, using the updated PY 2021 Public Reporting Template and Instructions. The updated template was posted to the ACO-MS on December 23, 2020 (refer to the Program Resources section).
CMS UPDATES MARKETING TOOLKIT AND BENEFICIARY NOTIFICATION TEMPLATES CMS has updated the ACO Marketing Toolkit and Beneficiary Notification Template; the updated materials are now available in the ACO-MS. CMS notes the updates to the beneficiary notification template are minimal and therefore, if your ACO has already proceeded using the old notices you may continue doing so. As a reminder, CMS has an annual Beneficiary Notification requirement in place that requires an annual notification to ACO beneficiaries regarding their participation in the ACO model.
CMS UPDATES SHARED SAVINGS/LOSSES SPECIFICATIONS WITH COVID-19 ADJUSTMENTS On December 23, CMS posted an updated Shared Savings/Losses Specifications document to reflect the additional adjustments that will be made in 2020 to address the COVID-19 Public Health Emergency (PHE). This resource reviews the changes made in two separate Interim Final Rules with Comment issued in 2020 to address the PHE. More information on these regulations is available on our COVID-19 resource page.
Welcome New Business Partner
Frier Levitt For 20 years Frier Levitt LLC, a national boutique health care and life sciences law firm, has assisted large medical practices and Accountable Care Organizations (ACOs) with a suite of legal services relating to value-based care contracting and contracts. Our services include value-based care contract due diligence, negotiation with payors, litigation avoidance and litigation. frierlevitt.com
MULTIPLE INNOVATION CENTER MODELS SEE DELAYS A federal judge in Maryland issued an injunction against a CMS Innovation Center program designed to tie the price of high-cost Part B drugs to what other countries pay. The Most Favored Nation Model was announced in November and was supposed to take effect on January 1, but the judge ruled that CMS failed to follow proper notice-and-comment periods before implementing the mandatory program. The model would pay the lowest Gross Domestic Product (GDP)-adjusted price for a drug paid by certain wealthy countries. The current add-on payment would be replaced with a flat payment uniform for all drugs in the model.
In the recent year-end spending bill, Congress delayed the Innovation Center’s Radiation Oncology Model until 2022 at the earliest. That was designed to test episodic payments for radiotherapy for 16 cancer types across 30 percent of fee-for-service Medicare. However, the Innovation Center’s ESRD Treatment Choices (ETC) Model, another mandatory model, is scheduled to go into effect on January 1.
CMMI POSTS RESULTS FROM DIFFERENT MODELS The CMS Innovation Center recently released the results of multiple models, including Comprehensive Primary Care Plus (CPC+) and the Accountable Health Communities Model. For the latter, a formal evaluation of the first year found the model, which tries to connect patients with community services, is effectively identifying higher cost and utilization beneficiaries. Early results show a 9 percent reduction in emergency department visits among Medicare fee-for-service beneficiaries, but no Medicare savings or effects on other outcomes in the first year. The Innovation Center also posted 2019 financial and quality results for the Comprehensive ESRD Care Model and CPC+. According to a summary of 2019 results, CPC+ practices retained 71 percent of their performance-based incentive payments.
