TOP ISSUES FOR ACOS TO WATCH IN 2021 Change is afoot this year in Washington as a new Congress and presidential administration bring different opportunities to advance ACOs and value-based payment. As we work to see what those changes hold, our health care system continues to fight the COVID-19 pandemic, which both challenges providers in alternative payment models (APMs) and demonstrates the importance of our work to improve the payment and delivery system. As NAACOS stands ready to help members learn and adjust to an ever-changing landscape, below are the top issues for ACOs to watch in 2021.
New Administration Begins The new year will bring new leadership throughout the Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS). While we still await word on who the nominee to lead CMS will be, California Attorney General Xavier Bacerra has been tapped to serve as HHS Secretary, pending congressional approval. Mr. Bacerra, the CMS Administrator nominee, and other new political leadership will go a long way to setting policy important to ACOs and others in value-based payment arrangements.
Congress Starts Work for 117th Session Even though a new Congress will give Democrats control over both chambers, the party will have the narrowest of majorities in both the House and Senate. Regardless, Democrats will be able to set the agenda in the Senate, giving them the chance to enact long-sought reforms to the Affordable Care Act through the budget reconciliation process.
Continued Focus on COVID-19; PHE Continues Despite the availability of a vaccine, the COVID-19 pandemic continues to rage in most parts of the country. Policymakers in Washington have granted a number of flexibilities to providers during the public health emergency (PHE), which was recently extended through mid-April 2021, including adjustments to certain ACO evaluations on cost and quality during the PHE. In 2021 the pandemic will bring continued and lasting impact to ACO programs. NAACOS will continue to assess the impact of the PHE on ACOs and advocate for policies that ensure fair evaluations of ACOs during this challenging time.
New ACO Quality Changes Go into Effect A new APM Performance Pathway (APP) takes effect in 2021 that includes a new quality scoring methodology for MSSP ACOs and new policies for how performance contributes to shared savings and losses. While the agency provides some flexibility for ACOs, including delaying the removal of the Web Interface reporting mechanism by a year, NAACOS continues to monitor the full effect that moving to the APP will have on ACO members, while we are also providing member education on how the new changes will affect ACOs in 2021 and beyond.
MACRA QP Thresholds Remain at 2020 Levels One thing that won’t be happening in 2021 is an increase of the Qualifying APM Participant (QP) thresholds. They were set to jump to unrealistic levels this year, but following NAACOS advocacy, Congress froze QP thresholds for both payment and patient counts at 2020 levels for the next two years. The result is that ACOs and other APMs have greater access to Advanced APM bonuses.
NAACOS Works on Reintroduction of the Value in Health Care Act While it remains to be seen where the new Congress places its emphasis in the coming year, NAACOS will continue to push lawmakers to adopt the Value in Health Care Act. The bill was first introduced in 2020 and would make several positive policy changes for ACOs and further incentivize participation in APMs.
Direct Contracting Model Moves Forward On April 1, CMS’s next premier accountable care model will formally launch when the first performance period of Direct Contracting starts. Fifty-one Direct Contracting Entities are participating in the implementation period, and more are expected to join for the April launch and 2022 start dates. NAACOS continues to develop education around Direct Contracting while working with CMS to help shape the model through our advocacy.
Other CMMI Models Begin The outgoing Trump administration was busy in 2020 finalizing a number of other CMS Innovation Center programs. Programs including Primary Care First, Comprehensive Kidney Contracting, Kidney Care First, ESRD Treatment Choices, and Emergency Triage, Treat, and Transport (ET3) Model are also slated to launch in 2021. Also, the rural-focused Community Health Access and Rural Transformation (CHART) Model has an ACO track that should begin accepting applications in 2021 for a 2022 start date. Meanwhile a new administration will likely also take an opportunity to evaluate these models and decide what changes may be necessary in the future.
Next Gen Model Sunsets This year is expected to be the sixth and final year for the Next Generation (Next Gen) ACO Model. While most Next Gens are gearing up to enter either Direct Contracting or MSSP in 2022, NAACOS has been pushing CMS to also make Next Gen a permanent addition to CMS’s suite of ACO options.
No New 2021 MSSP Class as Providers Wait for 2022 Opportunity NAACOS expects CMS to announce this spring information on applying to participate in the Shared Savings Program starting in 2022. This is an exciting opportunity given CMS canceled a potential 2021 MSSP class, citing the COVID-19 pandemic. NAACOS is pushing the incoming Biden administration to reverse that decision by providing a July 2021 MSSP start date.
GEORGIA SENATE RACES SHIFT BALANCE OF POWER On January 5, the state of Georgia held runoff elections for two U.S. Senate seats. In both races, Democratic candidates Raphael Warnock and Jon Ossoff won, resulting in a 50-50 split for the Senate overall. This means generally that Democrats will control the Senate for this Congress, since Vice President-Elect Kamala Harris has a deciding vote in the case of a tie in the Senate, barring any further fluctuation in Senate membership. Historically slim Congressional majorities have often resulted in increased bipartisanship and passage of moderate measures that are often less contentious. Democratic control of the Senate shifts the political landscape in Washington and gives President-elect Biden additional opportunities to pursue his agenda.
REGISTER FOR WEBINAR ON THE FEDERAL POLICY OUTLOOK Mark your calendar for NAACOS’ January 21st webinar reviewing the federal policy outlook in the year ahead. Presenters, which include NAACOS’ government affairs team and our lobbying consultants, will discuss healthcare priorities for a Biden-Harris administration including where value-based care is headed, work coming from Congress with narrow majorities in both chambers, and what policy priorities NAACOS plans to focus on in the coming year. Registration is free for NAACOS ACO members and Business Partners.
COVID-19 PHE EXTENDED THROUGH APRIL 2021 HHS Secretary Alex Azar recently renewed the COVID-19 PHE for a third time, extending the PHE through April 21. The 90-day declaration is effective on January 21, when it was set to expire. Aside from flexibilities provided to the entire health system such as through telehealth waivers, the PHE will hold ACOs harmless from financial losses for the percentage of months during the year in which the PHE is in effect. Also, CMS will remove COVID-19 episodes from ACOs’ expenditures. Both are critical to ACOs as concern should not be paid to patients’ spending when managing their care for COVID-19. NAACOS is very much appreciative of the PHE extension and the relief it provides. Additional COVID-related resources are available.
CMS RELEASES 2019 NEXT GEN ACO RESULTS NAACOS is proud to report that 37 of 41 Next Generation ACO Model participants collectively generated $559 million in gross savings in 2019 and $204 million after accounting for shared savings and loss payments and discounts paid to CMS. All but two Next Gens generated savings, according to the public use file released by CMS. Aggregate gross savings were 3.8 percent in 2019, compared to 1.4 percent, 2.5 percent and 0.9 percent in 2018, 2017, and 2016 respectively. Importantly, Next Gens had an average quality score of 93.7 in 2019. These 2019 performance year results reflect the hard work by many ACOs, and we congratulate ACOs on their success!
NAACOS issued a press release calling for the Next Gen program be made a permanent fixture in Medicare, either as a stand-alone program or an option within the Shared Savings Program, because of its successful track record. NAACOS encourages ACOs to tout their own savings and benefits to their respective communities and has developed a press kit to help your ACO get the word out about your performance. Please also send NAACOS your ACO’s press releases so that we can compile those on our ACO Member News page.
CMS RELEASES UPDATED 2021 MPFS CONVERSION FACTOR CMS recently released the revised and final Medicare conversion factor for 2021, which is $34.89. This key element of the Medicare formula for payments made through the Medicare Physician Fee Schedule (MPFS) was adjusted following passage of the Consolidated Appropriations Act, 2021 (H.R. 133). That package encompasses nearly $2.4 trillion in federal spending for 2021 and provides additional economic relief and stimulus in response to the COVID-19 pandemic. This comprehensive bill was passed by Congress and signed by President Trump in late December. A NAACOS has created a summary of the Consolidated Appropriations Act, 2021. That package provided an additional $3 billion in funding for the MPFS, designed to mitigate certain payment cuts. Following calculations by CMS, the agency released the updated 2021 conversion factor, which is an increase from what was included in the final MPFS rule. NAACOS recently updated our analysis of the final 2021 MPFS rule to reflect this.
2020 ACO QUALITY SUBMISSION PERIOD NOW OPEN The ACO quality submission period for Performance Year (PY) 2020 is now open. 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 contained the same patient sample that is made available through the Web Interface for the ACO. CMS will begin hosting Web Interface support webinars beginning January 27, 2021, from 1:00 to 2:30 p.m. ET; more information including registration details are provided in the ACO Spotlight Newsletters circulated to all ACOs. Finally, MSSP quality measure benchmarks for PY 2020 are now available on the CMS MSSP Guidance and Specifications page (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 a MSSP 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 circumstance, such as the COVID-19 PHE. Additionally, in the final 2021 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 MSSP ACO quality score for PY 2020.
Welcome New Business Partner
HealthCare Compliance Network, LLC HealthCare Compliance Network, LLC (HCN), is a healthcare compliance company that is led by industry pioneers, resulting in a distinct approach to compliance that blends extensive regulatory experience with the expertise to stay at the forefront of industry innovation. This approach enables us to develop comprehensive client solutions that are current and customizable to maximize the effectiveness of any compliance program. We alleviate the burden of compliance with our Hi-Touch, Hi-Tech approach and we work side-by-side with each client as a trusted partner. HCN specializes in helping clients avoid regulatory fines while maximizing revenues received for delivered services. hcompliance.com
UNDERSTANDING QPP’S ALL-PAYER COMBINATION OPTION ACOs participating in Advanced APMs are increasingly pursuing similar contracts with payers outside of traditional Medicare, and, as a result, there is increasing interest in the All-Payer Combination Option under the Quality Payment Program (QPP). NAACOS will host a webinar on January 29 at 2:00 pm ET to review this QPP option. We look forward to having CMS staff present about the All-Payer Combination Option, explain the benefits of this option, how the program works and how ACOs can earn QP status through participation in the All-Payer Combination Option. Register Today!
QUALITY SPECIFICATIONS RELEASED FOR DIRECT CONTRACTING The CMS Innovation Center has published more information on what measures will be used, how scoring will be conducted, and how measures will be weighted in the Professional and Global Options of the Direct Contracting Model. CMS plans to use fewer measures than it originally proposed; three claims-based measures in Performance Year 1 with two additional ones proposed for Performance Year 2. Some of the measures will only apply to certain Direct Contracting Entity (DCE) types. Whereas each measure will have its own benchmark, High Needs DCEs will have a separate set of benchmarks from Standard and New Entrant DCEs. NAACOS is reviewing the paper in greater detail and will provide more education on the topic later. All NAACOS’s Direct Contracting resources are available now.
ASSESS YOUR HIGH-VALUE CULTURE The Institute for Accountable Care (IAC) is currently working with the Kaiser Permanente Washington Health Research Institute and the ABIM Foundation to pilot a short survey that evaluates high value care attributes within ACOs. This three-to-five-minute, web-based survey is sent to clinical staff (e.g., physicians, nurse practitioners, and registered nurses). We are seeking ACOs who would like to try this tool. Respondents will be offered a small incentive for participating. We will also work with you to add custom questions you might be interested (e.g., practice site). ACOs can get access to their own data, obtain comparative results from other participating ACOs and participate in a free, one-hour webinar on how to support clinical value champions in your organization, hosted by Michael Parchman from the MacColl Center for Health Care Innovation at Kaiser Permanente. Participating ACOs will need to provide either an email list of clinicians who should receive a link to the survey or distribute the survey web link internally. If interested, please reach out to Jennifer Perloff and Leslie Valera (jperloff@institute4ac.org and lzv@institute4ac.org).
QPP POSTS QUALITY BENCHMARKS, NEW RESOURCES ON APP CMS has posted 2021 quality benchmarks for the Quality Payment Program (QPP), available on the QPP Resource Library (search ‘2021 Quality Benchmarks’). Additionally, CMS released an APM Performance Pathway (APP) fact sheet outlining the new APP methods for assessing ACO quality (for both MSSP and Merit-based Incentive Payment System purposes), which are effective in 2021. Read more about these new MSSP ACO quality assessment policies in our 2021 MPFS rule analysis (refer to the quality section) or view our on-demand webinar reviewing these changes.
CMS ISSUES STATE GUIDANCE ON VBP AND SDOH CMS recently issued guidance to state health officials designed to drive the adoption of strategies that address social determinants of health (SDOH) in Medicaid and the Children’s Health Insurance Program (CHIP). The guidance reviews how state Medicaid and CHIP programs can use a variety of delivery approaches and reimbursement methods to improve outcomes.
ONLY TWO WEEKS TO SUBMIT ENTRIES FOR NAACOS QUALITY AWARDS 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 are available. Should you have any questions, please contact us at advocacy@naacos.com.
CMS PUBLISHES ADDITIONAL CARE COORDINATION RESOURCES More case studies and toolkits for how ACOs operate the achieve their goals are available from CMS. Case studies include those from Nebraska Health Network on its data management system, OneCare Vermont on its care coordination programs, University of California San Francisco’s home care program, and Fresenius Kidney Care’s Home Dialysis Program. CMS has also published a toolkit that describes ACOs’ approaches to telehealth, home visits, timely access to skilled nursing facilities and other care transformation strategies. Additional case studies and toolkits can be found on CMS’s general information page about ACOs.
NAACOS BOOT CAMP IN LESS THAN TWO WEEKS — REGISTER NOW! Give your staff a leg up on building and maintaining successful programs in value-based care. Avoid travel cost and time away from the office and home by attending our virtual program with deep dives into the following topics and small group discussions to ask questions pertaining to your model/track. A detailed agenda with the times for each of the sections along with the speakers is now available! Register today for this unique opportunity to learn from experts who have successfully transitioned to value-based care. Pricing information is available as well.
