NAACOS LEADS COALITION LETTER TO CONGRESS ON VALUE
NAACOS and 11 other national health care organizations
sent a letter to lawmakers last week asking leaders
on Capitol Hill to maintain the movement toward value-based care in the new Congress. The letter outlines legislative priorities that will improve adoption of value-based care models,
including:
Extending value-based care incentives by extending the original 5 percent advanced Alternative Payment Model (APM) incentive payments,
Ensuring participants join and remain in value-based care models by removing barriers to APM participation,
Providing a more predictable pathway for more clinicians to engage in APMs by working with the CMS Innovation Center to ensure promising models have a better pathway to be implemented
and become permanent, and
Establishing parity between APMs and Medicare Advantage (MA) by seeking greater alignment between APMs and the MA program to ensure that both models can achieve success.
Welcome New ACO Members
MA-TDC GROUP ACO INC Novi, MI
Medical Home Network REACH ACO Chicago, IL
NAACOS PAC REPORT
The NAACOS Action Fund annual report is now available. The action fund is a political action committee (PAC)
that collects personal contributions from NAACOS members and staff to support congressional candidates who support value-based care. For more information on getting involved with the PAC,
please reach out to Aisha Pittman or
Robert Daley.
NEW POLICY RESOURCES FOR ACOS AVAILABLE
Check out three updated resources for ACOs:
The 2023 ACO Comparison Chart provides a side-by-side comparison of Medicare’s ACO program
tracks, including Basic Levels A — E and the Enhanced Track of MSSP and the Professional and Global Tracks of ACO REACH.
The 2021 Program Results Chartbook summarizes Medicare ACO financial and
quality performance results through 2021. NAACOS members interested in using this in their own presentations can email
advocacy@naacos.com for a copy of the PowerPoint file.
The ACO Guide to MACRA provides information on Quality Payment Program requirements – Merit-Based Incentive
Program (MIPS) and advanced APM incentive payments.
SHARE YOUR PATIENT SUCCESS STORIES
As part of our efforts to promote value-based care, NAACOS is collecting ACO success stories. We are looking for stories that highlight the positive impacts ACOs have on their patients and
communities. We will use these stories in our advocacy and public relations. Please share key details and a brief
summary of your story. NAACOS will follow up for additional information prior to using any of the information submitted.
LAST CHANCE FOR QUALITY AWARD SUBMISSIONS
The NAACOS Leaders in Quality Excellence Awards were established to recognize the outstanding efforts among ACOs working to improve the quality and safety of patient care and advance
population health goals. To be considered, submissions must be shared by end of day on March 3, 2023. NAACOS will recognize the top three submissions, selected by the NAACOS Quality Committee,
at our spring conference on May 3–5 in Baltimore. Please limit entries to one submission per ACO. More information on the award criteria and submissions process are included on our
website. If you have any questions, contact
advocacy@naacos.com.
JOIN NAACOS ECQM IMPLEMENTATION GROUP
NAACOS is convening a small working group of ACOs who are actively reporting or trying to report electronic clinical quality measures (eCQMs). This group will allow for shared learning and
also provide feedback to CMS regarding implementation challenges and successes. Interested ACOs should email
Jennifer Gasperini for more information.
CONGRESSIONAL UPDATES
CONGRESS PREPARES TO DEBATE FEDERAL SPENDING
Lawmakers on Capitol Hill are preparing to begin the annual appropriations process and debate increasing the federal debt limit. President Biden will send his budget request to Congress on
March 9. This will kickstart Congress’ work on drafting spending bills as lawmakers begin to field funding and programmatic requests from constituents and stakeholders. The Congressional
Budget Office (CBO) also issued a report last week projecting that, unless Congress increases the debt limit, the federal
government can only stay current on debt obligations through roughly September. CBO’s report also shows that Medicare spending will double over the next decade. While most lawmakers have said
cutting Medicare or Social Security is a non-starter, there will likely be more debate about the long-term viability of Medicare as insolvency becomes a more pressing issue. NAACOS continues
to educate lawmakers about how supporting the movement to value will help lower spending while increasing quality care for Medicare patients.
ADMINISTRATION UPDATES
MSSP APPLICATION DATES FOR 2024 PARTICIPATION ANNOUNCED
CMS recently published the MSSP application dates for agreements beginning January
1, 2024.
ACOs will not be required to submit a Notice of Intent to Apply (NOIA) to be eligible to submit a full application, unlike previous years.
Phase 1 of the application cycle will be open from May 18 – June 15, 2023, at 12:00 pm ET. Application dates are subject to change, NAACOS will continually monitor for changes.
You must register for the CMS ACO Management System (ACO-MS) to submit your application.
BPCI ADVANCED APPLICATION OPENS SOON
The CMS Innovation Center has reopened the application to participate in a two-year extension of the
Bundled Payments for Care Improvement (BPCI) Advanced Model. The bundled payment program will operate
in 2024 and 2025.
The application deadline is May 31 at 5:00 pm ET. More information, including the request for applications, can be found on the model’s
applicant resources webpage. The Innovation Center is holding a webinar on
the application process on March 9 at 2:00 pm ET. Registration is open.
As previously announced, ACOs are allowed to be conveners during this two-year extension. Through the Specialty Engagement Workgroup, NAACOS will discuss ACOs’ opportunity in this
model and other needed changes to allow ACOs to better engage specialists. Contact
Jennifer Gasperini for more information.
RECENT QUALITY MEASURE UPDATES
CMS recently made updates to certain quality measures for 2022. For ACOs reporting Screening for Depression and Follow-up Plan as a MIPS CQM, submission should only reflect measure data from
January 1, 2022, to September 30, 2022. The measure will be scored, but its performance truncated due to ICD-10 coding updates. Two Web Interface measures will not be scored (i.e., suppressed)
but still must be reported for ACOs reporting Web Interface measures: Depression Remission at Twelve Months and Statin Therapy for the Prevention and Treatment of Cardiovascular Disease. In
addition, two eCQMs will not be scored (i.e., suppressed) but still must be reported for ACOs reporting eCQMs: Screening for Depression and Follow-up Plan and Controlling High Blood Pressure.
CMS has updated the Performance Year (PY)
2022 APM Performance Pathway (APP) Toolkit to reflect
these changes (see the 2022 APP Scoring Guide). As a reminder the final day to submit PY 2022 quality data is March 31 at 8:00 pm ET.
CMS UPDATES 2023 CEHRT REQUIREMENTS FOR ACOS
As part of its annual Certified Electronic Health Record Technology (CEHRT) attestation, the ACO will need to attest to the percentage of eligible clinicians participating in the ACO that use
CEHRT to document and communicate clinical care to their patients and other health care providers. In Calendar Year 2023, the 2015 Edition Cures Update will be required to be used by eligible
clinicians participating in the ACO. CMS notes that while duration of use is not specified, ACOs should attest to CEHRT use that is current as of the date of attestation. The MSSP’s annual
CEHRT attestation shares the same CEHRT edition functionality requirements used in the Promoting Interoperability Program. To view a list of products that have been updated to the 2015 Edition
Cures Update, visit the Certified Health IT Product List (CHPL). The CEHRT attestation is completed during the MSSP’s signing
event annually.
NEW DRUG-FOCUSED MODELS COMING FROM CMMI
The CMS Innovation Center announced plans to launch three new drug models aimed at lowering the cost of prescription drugs. The move follows a White House executive order on lower drug costs
issued last year. The models include:
Encouraging Part D plans to offer a fixed $2 co-pay for a list of generic drugs that treat chronic conditions. This would be called the Medicare High-Value Drug List Model.
State Medicaid agencies would assign CMS to coordinate and administer outcomes-based agreements with drugmakers for certain cell and gene therapies, which can cost upwards of $1
million. This would be called the Cell and Gene Therapy Access Model.
CMS would develop payment methods for drugs approved under the Food and Drug Administration’s accelerated approval process to ensure Medicare-covered drugs have a confirmed clinical
benefit. This would be called the Accelerating Clinical Evidence Model.
More information can be found in this HHS report and
fact sheet. NAACOS continues to follow the Innovation Center’s work on
drug pricing, as Part B drug costs can be problematic for ACOs to control.
CMS ISSUES GUIDANCE ON FORTHCOMING PART B DRUG REBATES
As part of implementing the Inflation Reduction Act, CMS issued guidance for implementing enforcement of drug companies paying rebates to Medicare when price of drugs increases faster than the
rate of inflation. CMS is seeking feedback on the process to determine the number of drugs eligible for rebates, rebate amounts, assuring accuracy of rebates, and penalties for drugmakers for
failing to pay rebates. Medicare beneficiaries may begin paying lower coinsurance for certain Part B drugs starting April 1 if prices increase faster than inflation in first quarter of this
year. The Part B and
Part D guidance is available online along with a
fact sheet. Comments on both are due March 11.
Welcome New Business Partner
Biofourmis
Biofourmis is a nationwide virtual specialty care provider that leverages our FDA-cleared technology platform to:
Deliver efficient, cost-effective virtual cardiology care and care coordination for patients across all acuity levels
Provide comprehensive, technology-enabled Disease Management programs for patients with chronic conditions/diseases and
Engage with our partners in a value-based agreement construct.
NEW ACO MEMBER BENEFIT: UNDERSTAND YOUR SPENDING ON BPCI EPISODES
NAACOS in partnership with the Institute for Accountable Care is offering complimentary episode spending reports to all member ACOs. The reports are based on 2021 spending for each ACO’s
attributed beneficiaries grouped into 34 Bundled Payment for Care Improvement Advanced 90-day episodes. The reports provide aggregate results for each bundle by type of service along with a
state-level comparison group. The episode reports will show your ACOs:
The volume and average spending for each 90-Day BPCI clinical episode for your ACO’s attributed beneficiaries in 2021.
The relative ‘efficiency’ of the episodic care your beneficiaries received as indicated by the observed-to-expected ratio. This measure uses risk-standardized episode spending.
Per-episode spending for major categories of service such as skilled nursing and hospital readmissions for each episode.
Comparisons to your state’s average episode spending.
Sign up for our free webinar on March 7 to learn how to use this report! The Institute for
Accountable Care offers a variety of episode of care analytic services including reports with provider-level episode spending detail that can be performed under a separate agreement.
More information is available or you can contact
analytics@institute4ac.org
ACO MEMBERS: GET UNDER WAY WITH COMPLIANCE
NAACOS has released an updated MSSP Compliance Manual and a new ACO REACH Compliance Manual.
Why should you purchase the manual? ACOs are required to meet a large number of state and federal regulatory requirements, including health care fraud and abuse laws, privacy
requirements, and the specific requirements of CMS. This manual is a necessary tool designed to provide template policies to help your leadership determine the best “next steps” for your
organization and implement procedures to ensure compliance with program requirements. Your ACO may have purchased a previous version of this Compliance Manual. If so, upgrading to this newest
version will provide additional compliance and operational insight, as well as the addition of required policies around care coordination, beneficiary engagement, internal reporting on data
and analytics, marketing material requirements, and more!
NAACOS members may also join ACO compliance expert, Kimberly Busenbark, as she details the keys to implementing and operating effective compliance programs.
Webinars will be held on March 14 from 2:00 to 3:00 pm ET for the MSSP compliance manual and on March 16 from
2:00 to 3:00 pm ET for the REACH manual. Get actionable advice on best practices for required documentation as well as how to successfully navigate audits, avoid high risk areas, and work with
operations to set up compliant processes for your ACO. For the REACH webinar, Ms. Busenbark will also discuss updates from Direct Contracting to ACO REACH and the impact on operational
compliance. It’s easy to be compliant, join us to find out how to prove it when it matters most.
NAACOS RESOURCE REVIEW: ACO PUBLICATIONS
The NAACOS website features publications related to ACO operational, financial, and clinical needs that are available to
our ACO members. One recent publication is
So, You Want to Form a Health Care Network – Now What? which presents examples
of management’s considerations and processes within Keystone ACO. The paper provides positive and negative observations that can assist new networks in selecting participants, evaluating
opportunities, and providing the staffing resources to create a successful health care network. Find additional articles and publications that fit your ACOs’ needs by navigating to
ACO Publications under the resources tab on our homepage.
LEARN FROM OUR LISTSERVS’ MOST RECENT DISCUSSIONS
Your membership includes access to our exclusive ListServs for ACO members. These tools allow you to send messages and ask questions through a single email distributed to all ACO members
subscribing to the list! Here are the most recent discussion topics:
FULL AGENDA ANNOUNCED FOR SPRING 2023 CONFERENCE
Join us May 3–5 for the NAACOS Spring 2023 Conference at the Hilton Baltimore Inner Harbor. In addition to plenaries with CMS officials and other value-based care leaders, this two-day,
in-person event will feature 16 breakout sessions with actionable knowledge for new ACOs joining the MSSP and REACH models, rural ACOs, independent primary care ACOs, and experienced ACOs in
all models. The full conference agenda is now available, which includes dates and times for each breakout session. Virtual and in-person registration options are available and, as always, the
entire conference will be recorded. Pre-conference workshops will be held May 3 from 1:00 to 5:00 pm ET. We are offering three workshops for the spring conference, including:
ACO REACH: Implementation and Sustainability
Building the Foundation for ACO Success: MSSP Basics
Annual Wellness Visits
Register early and save! Register before March 17 for the in-person or virtual conference and receive a discount.
Exhibitor and sponsor opportunities are now available! The conference will feature exhibitors with products and services specifically for the accountable care community.
Partners reserve your space today!
MSSP BENEFICIARY NOTIFICATION DISCOVERY CALL
Join us on March 8, 2023, from 4:00 to 5:00 pm ET for a discovery call concerning the MSSP patient notification process. Jessica Martensen, VP of population care management programs at
Essentia Health, will provide an overview of Essentia’s process. Following her presentation, we will provide an opportunity to discuss suggestions, questions, or concerns about the current
requirements. Sign-up to join the MSSP Beneficiary Notification Discovery Call.
MEDICAID LEARNING LAB MONTHLY MEETINGS CONTINUE
The Medicaid Learning Lab series is still open for new participants. Sign up before the next meeting on March 3, 2023, at
2:00 pm ET. The virtual learning lab meetings in this series began December 2, 2022, and will continue in monthly 90-minute sessions through December 2023. The Learning Lab provides content on
value-based care models to support your contracted populations and networks, various Medicaid models throughout the states, workflow options for value-based care related to primary care,
social determinants of health, behavioral health, and high needs people, plus how to improve quality in the Medicaid population and how to enhance patient engagement in the Medicaid
population. As we know, children comprise a large portion of the Medicaid population, especially those with both severe acute, congenital, or chronic acquired conditions. This month Lisa
Adkins, AVP VBSO Medical Management and Clinical Revenue Cycle at Nemours Children’s Health, will present ‘Care Models Supporting Contract Populations and Networks and Workflow Options for
Value Based Care.’ We are now offering CEUs for learning lab participants who attend at least 75 percent of the meetings.
WINTER VIRTUAL AFFINITY GROUPS WINDING UP
Don’t miss your opportunity to join the executive and the clinical affinity groups. The Executive Affinity Group is
led by Jen Moore and Jake Woods. The 2023 meetings include February 23, July 25, and November 21 from 3:00 to 4:00 pm ET, as well as in-person sessions for those attending the spring and fall
conferences. Participants should be CEOs, CFOs, executive directors, chief value officers, and others who oversee the ACO’s finances, budget, strategy, contracting, etc.Sign up for the
Executive Affinity Group. The
CMO and Clinical Affinity Group is led by Nina Taggart, MD, and David Van Winkle, MD. The 2023 meetings include
March 2, August 1, and November 28 from 3:00 to 4:00 pm ET, as well as in-person sessions for those attending the spring and fall conferences. Participants should be CMOs, CNOs, population
health officers, and others who manage patient care, clinical care redesign, etc. Sign up for the
Clinical Affinity Group.
WHAT WE’RE WATCHING
The Health Affairs Council on Health Care Spending and Value, which convened 21
health policy experts on lowering the cost of care, issued its
recommendations, including those around advancing
value-based care. The council called for continued experimentation.
A recent CMS blog highlights the agency’s efforts to address rural health inequities
in Medicare. In the blog, CMS describes efforts to support rural providers, improve access to care through telehealth, and transform the rural health delivery system. Advance
investment payments for certain new MSSP ACOs, which were finalized in the 2023 Medicare Physician Fee Schedule and will be made available beginning January 1, 2024, are intended to
encourage rural providers to form and join ACOs.
March2–3: The Medicare Payment Advisory Commission (MedPAC) public meeting. Virtual only.
March 2–3: Physician-Focused Payment Model Technical Advisory Committee (PTAC)
public meeting on specialist integration within population based total
cost of care models.
June 7–8: CMS Health Equity Conference. Virtual and at Howard University’s Armour J. Blackburn University Center.
Registration will open soon.
