NAACOS Newsletter for Members and Partners February 24, 2022

Table of Contents

Stakeholders Call on HHS to “Fix, Don’t End” Direct Contracting
Meena Seshamani to Open NAACOS Spring Conference
NAACOS to Launch Learning Lab on Specialist Integration
Ask Your Representatives to Join Letter Supporting ACOs by March 1
CMS Withdraws Rural-focused ACO Model
New Research Shows Exiting MSSP Leads to Lower Quality Care
Congress Mulls Upcoming Deadlines
Institute Update: ACOs and Geriatric Emergency Departments
Bundled Payment Expert Joins the Institute
Updated MSSP Specifications Released
NAACOS New Health Equity Webinar Available On-Demand
NAACOS Submits Statement to Ways & Means on Health Equity
Lawmakers Call on Administration to Wind Down PHE

STAKEHOLDERS CALL ON HHS TO “FIX, DON’T END” DIRECT CONTRACTING
NAACOS thanks all those members who signed a letter to Health and Human Services (HHS) Secretary Xavier Becerra urging him to “fix, don’t end” Direct Contracting. At the end, 222 organizations including prominent trade groups, like NAACOS, health systems, medical practices, Direct Contracting Entities (DCEs), ACOs, and others, signed the letter. NAACOS had heard Secretary Becerra and the White House were weighing the future of Direct Contracting, including the possibility of canceling the program, following backlash from advocates and progressive Democrats on Capitol Hill. We are now cautiously optimistic that our advocacy will prevent the model from termination, and we expect more information from CMS soon.

As the premier accountable care model from the CMS Innovation Center, Direct Contracting is needed to help redesign healthcare delivery and payment. We continue to work with Capitol Hill and the administration to garner support. We will alert members when we have more clarity about the model’s future, but for now, we expect numerous policy details to be announced next month after a statement of support from CMS in the next few days.

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MEENA SESHAMANI TO OPEN NAACOS SPRING CONFERENCE
Dr. Meena Seshamani, Deputy Administrator and Director of Center for Medicare is confirmed to open the NAACOS Spring 2022 Conference with a keynote on Thursday, April 28 at 8:30 a.m. Join us at the Hilton Baltimore Inner Harbor and hear from her and other leading value-based care experts and CMS officials sharing timely and essential information for ACOs and other alternative payment models (APMs). The conference will also include our peer-to-peer exchanges, quality award winners, and the popular CMS Townhall to close out the conference. A detailed agenda is now available.

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.

NAACOS TO LAUNCH LEARNING LAB ON SPECIALIST INTEGRATION
NAACOS is launching a Learning Lab on Specialist Engagement and Incentives on April 27 at the Hilton Baltimore. Learning Labs are a new educational activity for members designed to provide a deep dive into fundamental strategies in accountable care and to foster exchange among peers with frontline experience. These interactive “labs” will include expert presentations, experiences from member ACOs, brainstorming activities, and peer-led collaborations. NAACOS will be an active partner in these Learning Labs to understand what additional resources and tools members need to work through various administrative, operational, and transformational processes.

Due to great interest from our membership, Specialist Engagement and Incentives will be the topic for our inaugural Learning Lab session kicking off this April with more activities and resources to follow throughout 2022. Watch for further information on participating in the next newsletter.

NAACOS RESOURCE REVIEW

Questions about the 2021 MSSP quality reporting process?
With only five weeks left to complete MSSP 2021 quality reporting, NAACOS would like to remind ACOs of the resources available on our Quality page that may help with your submission. For 2021, ACOs may choose to report either via Web Interface or via electronic clinical quality measures (eCQMs)/Merit-Based Incentive Payment System CQMs. All ACOs will have new scoring rules applied as the MSSP transitions to the APM Performance Pathway (APP) quality scoring methods beginning with Performance Year (PY) 2021. The resources found on the NAACOS Quality page include links to the NAACOS Web Interface Quality Guide, completed in 2020, CMS guidance and fact sheets, Web Interface specification documents, and the Quality Payment Program (QPP) resource library, as well as the NAACOS guide to accessing eCQM specifications. In addition, we provide an overview of the APP for ACOs in our new resource that explains new quality reporting requirements and scoring rules for 2021–2025.
ASK YOUR REPRESENTATIVES TO JOIN LETTER SUPPORTING ACOS BY MARCH 1
The leaders of the House Innovation Caucus are asking their House colleagues to join them in sending a letter requesting that the Biden administration prioritize policy changes that will increase ACO participation. The deadline for lawmakers to sign the letter is March 1. NAACOS has been asking our members to write their representatives to ask them to sign the letter. We support the recommendations in the letter and believe these changes will advance the Biden administration’s goals of expanding accountable care.

CMS WITHDRAWS RURAL-FOCUSED ACO MODEL
CMS announced this week it was formally withdrawing the ACO Transformation Track of the rural-focused Community Health and Rural Transformation (CHART) Model. This Innovation Center model would have given up-front funding to 20 mostly rural providers to form ACOs. Despite the announcement from CMS, NAACOS is optimistic that CMS will launch a separate model to spur ACO development. Unlike CHART, this new model would have a strong emphasis on addressing equity, and NAACOS has been in touch with CMS around details of that model. NAACOS also believes CMS could certify the ACO Investment Model, which has already been proven to save Medicare money and improve quality. The agency says it remains committed to ACOs and has set a goal to have all traditional Medicare beneficiaries into an accountable care model by 2030.

NEW RESEARCH SHOWS EXITING MSSP LEADS TO LOWER QUALITY
A recent study shows that exiting the Medicare Shared Savings Program (MSSP) was associated with lower rates of preventive services, resulting in lower quality of care after the practice’s departure from the program. The study looked at a cohort of more than 1.7 million beneficiaries. The reductions in clinical quality after leaving the MSSP were found to be most prominent in the first two years after exiting the program. After exiting the MSSP, the study shows patients were less likely to receive important preventive screenings, particularly those associated with managing diabetes and cardiovascular disease, for example. This study demonstrates the importance of maintaining high levels of participation in the MSSP and similar models.

CONGRESS MULLS UPCOMING DEADLINES
Congress is in recess this week after passing a temporary extension of federal funding at a February 17 Senate roll call vote of 65 yeas to 27 nays. The measure provides funding for the federal government through March 11, setting up a quickly approaching deadline for Congress to come to bipartisan agreement on a Fiscal Year 2022 appropriations package or pass another temporary funding measure. Also upcoming, the 2 percent sequester cut delayed by Congress last December, which was a significant concern for Medicare physician payment, will be partially effective on April 1 with a 1 percent cut going into effect. And, last week the Biden administration put forward its budgetary request to Congress on health-related items but did not include approximately $20 billion in provider relief funding requested by hospital associations. Of note, underlying Congress’ efforts to meet impending deadlines and resolve issues related to funding and the public health emergency (PHE), is the escalating situation in the Ukraine and Congress’ urgent efforts on that issue.
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INSTITUTE UPDATE: ACOS AND GERIATRIC EMERGENCY DEPARTMENTS
Geriatric emergency departments (GEDs) are a new model established to enhance the care experience for vulnerable older adults and reduce potential harms, including avoidable admission, in the fast-paced ED environment. Today, there are more than 300 certified GEDs, and 20 percent of ACOs have at least 1,000 GED visits per year. This creates a natural opportunity for partnerships given the common goal of preventing avoidable hospitalizations. To learn more, see our paper published last week in Health Affairs. Other recent publications include a discussion of challenges facing ACOs in the transition to ECQMs, a proposal to extend and enhance the Advanced APM bonus program, and a summary of the literature on the characteristics and performance of ACOs. If you would like a copy of these papers use the links above or contact us at: [email protected].

BUNDLED PAYMENT EXPERT JOINS THE INSTITUTE
The Institute for Accountable Care is pleased to announce that Dan Koppel has joined its team as director of applied analytics. Over the past decade Dan has worked at several firms including Remedy Partners and New Century Health developing analytical software produces focused on bundled care pricing, care optimization and risk modeling for clinicians in the CMS Bundled Payment for Care Improvement and Oncology Care Models. Dan’s work will focus on expanding the Institutes capabilities to use episode of care analytics to evaluate the performance of specialty care providers.


UPDATED MSSP SPECIFICATIONS RELEASED
CMS has released an updated Shared Savings and Losses and Assignment Methodology Specifications document for MSSP (Version 10). The resource includes updates on the MSSP beneficiary assignment and financial methodology for PY 2022 to reflect policies finalized in the 2022 Physician Fee Schedule Rule. The resource can be accessed on the CMS website under the resources section.

NAACOS NEW HEALTH EQUITY WEBINAR AVAILABLE ON-DEMAND
On February 15, NAACOS hosted a webinar titled How ACOs Are Addressing Health Equity: Insights from Innovators during which speakers from Advocate Aurora Health, Aledade, and Mount Sinai Health System highlighted the work they are doing to close health equity gaps among their populations. A recording of the webinar and a PDF of the slides are now available on-demand. Speakers shared key insights from their experiences designing and implementing health equity initiatives within their ACOs. The webinar recording also includes a robust panel discussion followed by audience questions. This webinar is part of ongoing work by NAACOS to engage in conversations around health equity and explore how APMs can facilitate health equity initiatives, as well as to highlight the important work ACOs are doing to reduce health inequities.

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NAACOS SUBMITS STATEMENT TO WAYS & MEANS ON HEALTH EQUITY
Recently, NAACOS submitted a statement for the record to the House Ways & Means Committee in response to the recent Health Subcommittee hearing on bridging health equity gaps for people with disabilities and chronic conditions. In this statement, NAACOS described the history of ACOs’ work to provide high-quality, coordinated, and whole-person care to patients with complex health needs through care management and other strategies. Additionally, we highlighted how ACOs are uniquely positioned to identify and address health inequities and how they are incentivized to address social factors affecting the health outcomes of their patients. NAACOS urged the committee to consider the Value Act as an opportunity to strengthen ACOs’ ability to engage in this work and to grow the program so that the benefits of accountable care are accessible to more beneficiaries.

LAWMAKERS CALL ON THE BIDEN ADMINISTRATION TO WIND DOWN PHE
As more states move to loosen COVID-19 restrictions, calls from lawmakers in Washington are increasing to end the federal government’s PHE, which has been extended numerous times and is currently scheduled to expire on April 15. While the Biden administration is expected to extend the PHE at least once more this year and provide a 60-day notice to stakeholders before termination, a group of more than 70 congressional Republicans wrote a letter on February 10 asking the Biden administration to outline its timeline for ending the PHE. The letter also asks for HHS to identify which emergency flexibilities should be made permanent.

CMS has implemented several regulatory flexibilities for ACOs during the PHE, along with temporary telehealth policies that will expire at the end of the emergency. NAACOS sent a letter to HHS last year asking for the Biden administration to modernize telehealth requirements and provide permanent waivers for all ACOs, regardless of risk level or choice of attribution. There continues to be bipartisan support in Congress for making permanent changes to telehealth policies. NAACOS’ will continue to monitor the administration’s decision making and alert members to any extension or the possible end of the PHE.