REGISTER
FOR UPCOMING HEALTH EQUITY WEBINAR NAACOS
invites everyone interested in health equity to join us for an exciting webinar we
have planned for February 15 at 11:00 am ET. This webinar is part of ongoing work by
NAACOS to engage in conversations around health equity and explore how alternative
payment models can facilitate health equity initiatives. While there are significant
barriers to addressing health inequities, many ACOs are undertaking a range of
efforts to close health equity gaps and meet patients’ nonmedical needs in order to
improve their health and well-being. In this webinar, titled How ACOs Are Addressing
Health Equity: Insights from Innovators, we will explore addressing and improving
equity in value-based care. Speakers from Advocate Aurora Health, Aledade, and Mount
Sinai Health System will highlight how the ACO model can be leveraged to address
health equity, sharing challenges and lessons learned through the planning and
implementation of equity-focused initiatives. Members and partners are free, all
others are charged $195. Register now!
Welcome
New Business Partners
Community
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Healthmap
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SPRING
CONFERENCE AGENDA NOW AVAILABLE Join us on
April 27–29 at the Hilton Baltimore Inner Harbor and hear from leading
value-based care experts and CMS officials sharing timely and essential information
for ACOs and other alternative payment models. A detailed agenda is now
posted and will feature breakout sessions on:
Critical Policy Update for ACOs and DCEs
Increasing Health Equity
Quality Management Across Contracts
Using Data in Benchmarking
Clinical Transformation Through Data
Annual Wellness Visits
Using Episodes of Care to Evaluate Specialist Performance
Digital Care Including Remote Monitoring
Understanding Direct Contracting Compliance and Operations
Effective Contracting Strategies with SNFs
The
conference will also include our peer-to-peer exchanges, quality award winners, and
the popular CMS Townhall to close out the conference.
Two
pre-conference workshops*
on April 27 from 1:00 to 5:00 pm can enrich your conference learning with actionable
strategies for your ACO’s success. The two workshops will be:
Expedite the Learning Curve for Success in Medicare Advantage led by Kim
Kauffman
Conundrums in Care: Innovative Post-Acute Strategies led by Jessica Martensen,
Essentia Health
*These
workshops require separate registration from the main meeting.
Register
Early and Save Register before March 4 for the in-person
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. Proof of vaccination required to attend
in-person.
Group
Rates 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. Group rates are only available to NAACOS member ACOs and
DCEs. If your organization is not a member, join now and save!
CONGRESSIONAL
LAWMAKERS EMBRACE SHORT TERM, MIDDLE GROUND Democratic
Senator Ben Ray Lujan (D-NM) suffered a stroke last week, effectively
decreasing the Senate majority from a 50–50 Senate (with a majority vote
from Vice President Kamala Harris) to a 50–49 Senate. Lujan’s absence,
combined with periodic illnesses on both sides of the aisle due to
COVID-19, complicates the Senate Majority’s ability to move
controversial legislation and/or President Biden’s political appointees
and is likely to put the already stalled Build Back Better agenda on the
back burner for the next several weeks. At the same time, some
bipartisan efforts, including election reform and limitations around
required pre-trial arbitration for sexual assault, are highlighting the
effectiveness of bipartisan work on issues, at least in the
slim-majority Senate. Like the bipartisan passage of the infrastructure
funding bill earlier in President Biden’s term, the successful
advancement of several bipartisan policies has undermined partisan
strategies.
This week, the House is likely to pass a
short-term funding bill after negotiations among appropriators failed
over the weekend. Funding for the federal government is set to expire on
February 18, and it is anticipated that Congress will pass a 30-day
continuing resolution (CR) to stave the budget expiration. After the
House passes its measure, a CR would also require Senate passage, likely
to occur late this week or early next. At the same time, Congress is
continuing its work on the America Creating Opportunities for
Manufacturing, Pre-Eminence in Technology, and Economic Strength
(COMPETES) Act of 2022 (House version), or U.S. Innovation and
Competition Act (Senate version), which includes some provisions on
information technology, digital health, and research of interest to
healthcare stakeholders—that measure passed out of the House last week
and the Democratic Majority will seek to reconcile the House and Senate
versions. This Thursday, the Senate Health, Education, Labor and
Pensions (HELP) Committee will meet for a hearing on healthcare
workforce issues after numerous organizations have pushed over the last
several weeks to highlight clinician and administrative worker shortages
in health centers nationwide. The House Energy and Commerce Committee
will also meet for a hearing on Tuesday regarding the creation of an
Advanced Research Projects Agency for Health (ARPA-H) to fund research
for innovative healthcare technologies and therapies.
ASK
YOUR CONGRESSIONAL REPRESENTATIVES TO SUPPORT ACOS Several
members of the House of Representatives are sending a letter with colleagues asking
the
Biden administration to adopt common-sense policies to increase ACO
participation. NAACOS is asking
our members to write their elected officials today
encouraging them to join the letter! To achieve the goal of
having every Medicare beneficiary in an accountable care model by 2030,
CMS and the Innovation Center must work to grow provider participation
in ACOs and other alternative payment models (APMs). NAACOS feels the
recommendations in this letter would do that, and we appreciate the
Innovation Caucus’s leadership on drawing attention to these important
issues.
NEXT
DC LEARNING DISCUSSION SCHEDULED FOR FEBRUARY 18 NAACOS
is holding its next Direct Contracting (DC) Learning Discussion on
February 18. As a reminder, these monthly events are meant for direct
contracting entities (DCEs) to share feedback, questions, concerns, and
points of interest. Participation is limited to those participating in
the model in 2022, and as such, advanced registration is required.
If you have questions or topics of conversation you want discussed,
please share them in advance by emailing
us. The point is to make these collaborative discussions and a
forum for shared learning. We ask that you come prepared to share your
questions and perspectives and to react to issues at hand.
QUESTIONS
ABOUT HOW AND WHEN TO TAKE ON MORE RISK? It
will soon be application season and many ACOs who are working on the
risk strategy and trajectory of their ACO for 2023 may be questioning
how to best approach taking on more risk. NAACOS will hold a webinar on
February 22 at 2:00 pm titled Navigating through Shared Risk Contracting
to provide insight and tips for this process. This webinar will discuss
why taking on risk could be the best move for your providers to support
the transition from fee-for-service to value-base payments through the
utilization of CMS programs. Content will include how to navigate the
Medicare Shared Savings Program (MSSP) program to increase risk to the
highest risk enhanced track and beyond, how to get involved and play a
role in the transition to increased risk, and what the benefits can be
to your organizations and practices. Session presenters will include
Shawn Bassett, VP Program Operations, and Jim Piccillo, VP of Business
Development form Collaborative Health Systems. The webinar is free for members and business
partners and $195 for non-members.
NAACOS
RELEASES UPDATED ACO COMPARISON CHART Recently,
NAACOS published an updated edition of the MSSP ACO Comparison Chart. This helpful
resource
details key program elements and highlights similarities and differences
between the current participation track options in MSSP. The chart
examines general track details, financial policies, quality reporting,
and compliance and waiver policies, reflecting policies in place for
Performance Year (PY) 2022. Importantly, this edition of the chart
includes key changes to quality reporting requirements that were
finalized in the Final 2022 Medicare Physician Fee
Schedule. More details about the new quality
requirements
are available.
CMS
RELEASES 2023 MA AND PART D ADVANCE NOTICE CMS
is proposing to increase payments to Medicare Advantage (MA) plans by an
average of nearly 8 percent in 2023. That includes a 4.75 percent growth
rate and average risk score increase of 3.5 percent before
normalization. By comparison, MA plans received an average payment
increase of about 4 percent in 2022. MA continues to receive huge
amounts of bipartisan support, as evinced by a recent letter signed by
346 members of Congress or roughly 80 percent of the chamber, which is
translating into generous payment rate increases. Comments are due by
March 4 with an expected final regulation by April 4. The fact sheet and advance notice are published online.
Of interest, CMS says it is considering a new measure to capture
value-based care arrangements that MA plans have with providers,
including risk sharing, bonuses or penalties based on meeting
performance targets, and non-financial resources to drive outcomes and
lower costs. CMS also solicits feedback on the effects of patients’
social determinants of health on risk scores. Lastly, CMS is considering
the development of a Health Equity Index to potentially change Star
Ratings to better take into account how plans advance health equity.
Potential measures include how often plans are screening for common
health-related social needs, such as food insecurity, housing
insecurity, and transportation problems.
In 2023, CMS
proposes to apply a 5.9 percent coding pattern adjustment, which is the
minimum adjustment required by statue. While CMS typically normalizes
risk scores to better average risk scores’ increases, CMS is not basing
2023’s normalization factor on 2021 risk scores, which is based on dates
of service from 2020, because of concerns around the COVID-19 pandemic.
NAACOS
AND OTHERS CALL ON CONGRESS TO STRENGTHEN APM INCENTIVES NAACOS
and other leading value-based care stakeholders urged Congress to do
more to encourage the adoption of APMs in Medicare to improve patient
care and prolong the Medicare Trust Fund. In a statement for the record provided to
the
Senate Finance Committee on its recent hearing, further described in the article
below, regarding the Hospital Insurance Trust Fund and the Future of
Medicare Financing, the groups point to evidence that ACOs improve
quality and patient outcomes while having successfully lowered the rate
of spending growth in Medicare. The statement also calls on Congress to
extend the Advanced APM bonus for an additional six years and give the
HHS Secretary greater discretion to determine thresholds providers must
reach to receive those bonuses. These bonuses have been instrumental in
encouraging participation in risk-based APMs, but 2022 is the last
performance year in which ACOs and other Advanced APM participants can
qualify to earn the bonus. NAACOS is working hard to advocate that
Congress extend these bonuses and encourage more providers to enter into
ACOs and APMs that have proven to provide Medicare patients with better
quality care at lower costs.
SENATORS
DISCUSS ACOS DURING CONGRESSIONAL HEARING ON MEDICARE TRUST
FUND During
a Senate Finance Committee hearing last week on
the Medicare Trust Fund, Senator Sheldon Whitehouse (D-RI) spoke about
how ACOs are leading the Medicare value-based care transformation,
resulting in better quality care and saving the Medicare program money.
Senator Whitehouse has been a champion of ACOs since the program’s
inception nearly 10 years ago. He reaffirmed his support during the
hearing and called on his senate colleagues to come together to further
strengthen the program and increase participation. NAACOS looks forward
to working with Senator Whitehouse and members of the committee to
continue improving Medicare’s accountable care programs. Senator
Elizabeth Warren (D-MA) also called on the Biden administration to end
the Direct Contracting Model, claiming it would privatize Medicare.
NAACOS disagrees with her comments, supports the model, and is reaching
out to her office to discuss her concerns.
SNAPSHOT
OF 2021 QP STATUS AND APM PARTICIPATION DATA NOW POSTED CMS
recently updated the Quality Payment Program (QPP) participation status tool to reflect the
third PY 2021 evaluation for meeting Advanced APM thresholds, known as
Qualifying APM Participant (QP) thresholds. This third snapshot period
covers January 1 through August 31, 2021. This is the second QP
evaluation for DCEs, which covers April through August 31, 2021. QP
providers must receive at least 50 percent of their Medicare Part B
payments or see at least 35 percent of Medicare patients through an
Advanced APM entity to be eligible for a 5 percent bonus paid in 2023.
As previously reported in our November newsletter, more
providers in ACOs and DCEs will be eligible to earn these bonuses as a
result of NAACOS’ advocacy to prevent the QP
thresholds
from sharply rising in 2021. To learn more about these bonuses, QP
thresholds, and how to qualify, please refer to NAACOS’ resource, The ACO Guide to MACRA.
NAACOS
JOINS OVER 50 ORGANIZATIONS ON LETTER TO SENATE COMMITTEE Last
week, NAACOS signed onto a letter with more than 50
other organizations, which was sent to the Senate HELP Committee
requesting that the committee include key social determinants of health
(SDOH) provisions in the recently-proposed Prepare for and Respond to
Existing Viruses, Emerging New Threats, and Pandemics Act (PREVENT
Pandemics Act). The letter, led by Aligning for
Health, suggests that the full text of the bipartisan Leveraging
Integrated Networks in Communities (LINC)
to Address Social Needs Act (S. 509/H.R. 6072) should be
included in the legislation. NAACOS endorsed the LINC to Address Social Needs
Act when it was introduced in the Senate and the House during 2021. This
bill would support cross-sector efforts to coordinate and address
health-related social needs by providing funding to build or enhance
sustainable closed-loop referral networks in order to coordinate
effectively between physical and behavioral health care and social
services and community-based organizations.
CMS
RELEASES PRELIMINARY 2020 QPP RESULTS CMS
recently published preliminary results for QPP PY 2020. Important
trends include a 21.3 percent increase in the number of Qualifying APM
Participants (QPs) from 2019 to 2020, with 25.4 percent of Merit-Based
Incentive Payment System (MIPS) Eligible Clinicians meeting QP status for
2020. This is the highest number of QPs since the start of the program.
Those clinicians who met QP status for 2020 will be awarded a 5 percent
Advanced APM bonus payment in payment year 2022. Under current
interpretation of the Advanced APM bonus payment program, the bonus is only
earnable through December 31, 2022. NAACOS is advocating that Congress act
expediently to extend the Advanced APM bonus in order to ensure continued
growth in Advanced APM participation. NAACOS has drafted an editable letter
so that you can write your member of Congress today to urge them to
support this extension!
Additionally, participation in MIPS
APMs decreased by approximately 4.2 percent for a total of 398,719
participants in 2020. We also see an increase in final MIPS scores, with the
average score reaching 89.41 and a median score of 96.82. Please note this
refers to final overall MIPS scores, not the MIPS quality performance
category scores that MSSP ACOs are compared with under the new quality
performance threshold. More information on the recent changes to
quality
reporting and scoring for MSSP is available. It is important to note, these
preliminary results are based on data that has not yet undergone targeted
reviews, and the final participation results will be available in the coming
months. If you have specific questions for the QPP, you can email QPP@cms.hhs.gov.
NAACOS
SUPPORTS CMS’S PROPOSED LIMITED COVERAGE OF ADUHELM NAACOS
in a letter
submitted this week urged CMS to finalize its proposed National
Coverage Determination (NCD) for monoclonal antibodies that target amyloid
for the treatment of Alzheimer’s disease. A proposed NCD published on January 11 would cover
Aduhelm (aducanumab), the first FDA-approved drug to treat Alzheimer’s
Disease in more than 20 years for people with Medicare only if they are
enrolled in qualifying clinical trials. Expressing concerns that the
expected costs of Aduhelm, which was approved on June 7, would outweigh its
clinical benefits, NAACOS was supportive of the narrow proposed NCD until
more scientific evaluations exist to support the drug’s efficacy. The list
price of $28,000 per person for a year of treatment is nearly two-and-a-half
times the average ACO’s benchmark. While not necessarily part of CMS’s work
on an NCD, NAACOS also urged CMS to adjust ACO benchmarks to mitigate
Aduhelm’s cost.
2021
QUALITY REPORTING DUE MARCH 31 The
MSSP quality submission process for PY 2021 will close on March 31, 2022. As
a reminder, 2021 is the first year the APM Performance Pathway (APP) scoring
rules apply to all MSSP ACOs. Under the new APP structure, for PY 2021, MSSP
ACOs can choose to report either 10 Web Interface measures or three
electronic clinical quality measures (eCQMs) or MIPS CQMs (supported by a
registry). Reporting will take place via the QPP website. CMS advises ACOs
to ensure they have the necessary Health Care Quality Information System
Access Roles and Profile (HARP) accounts. ACOs can manage their HARP user
roles in the ACO Management System (ACO-MS). This includes ensuring the ACO
has a QPP Security Official listed in the ACO-MS. CMS has provided tip
sheets and user guides to assist with this process, available in the ACO-MS.
Access our new resource to learn more about your ACO’s
quality
reporting options for 2021 through 2025, as well as important changes to
quality scoring that can have significant impact on your ACO and your shared
savings.
