TOP ISSUES FOR ACOS TO WATCH IN 2020
A fresh decade is sure to bring several new, important issues for ACOs and a new spin on familiar topics. Changes ushered in by the Centers for Medicare & Medicaid Services (CMS) to the Medicare Shared Savings Program (MSSP) in 2018 begin to take root, while policymakers and providers look for ways to advance value-based care. NAACOS is ready to help members learn and adjust to this dynamic landscape. Below are the top issues for ACOs to watch in 2020.
- Congress prepares for busy year
As we enter 2020, both the Senate impeachment trial and elections are likely to take up a lot of oxygen on Capitol Hill. Nonetheless, there will likely be significant healthcare legislative activity, particularly in the first half of the year leading up to May when funding for certain Medicare and Medicaid extenders is set to expire. This brings an opportunity for Congress to tackle other healthcare issues, including prescription drug costs and surprise medical billing, which were main topics in 2019 but remain unresolved.
- Federal legislative efforts on value-based care gain traction
NAACOS is pushing a number of issues on Capitol Hill and expects to see further traction on these efforts in 2020. For example, NAACOS has been instrumental in advancing legislation (S.2648/H.R. 5212) that would fix a flaw in ACO benchmarking by removing an ACO’s assigned patients from the regional component of benchmarks. Importantly, NAACOS is also continuing to work with our congressional champions and coalition partners on comprehensive legislation to boost MSSP success and spur adoption of advanced alternative payment models, which we aim to have introduced in early 2020. Other key NAACOS focus areas include supporting the Chronic Care Management Improvement Act (H.R. 3436) and evaluating CMMI-related legislation, among others.
- 2020 Elections will focus on and affect health care
This November, Americans will head to the ballot box for elections that will decide who has control in both chambers of Congress and the White House. Health care will surely be a prime issue, as it’s usually a top issue for voters, and key topics will include ideas around “Medicare for All,” decreasing healthcare costs, and the fate of the Affordable Care Act (ACA). For the latter, the Texas v. Azar case, which continues to make its way through the courts and threatens to invalidate the ACA altogether, will be hotly contested, and the case could be argued before the Supreme Court later this year.
- First full year of “Pathways to Success”
CMS’s “Pathways to Success” regulation, which included a significant overhaul of the MSSP and has ACOs take on more risk sooner, starts its first 12-month performance period in 2020. The 2019 MSSP class, which was subject of a quick application deadline and July 1 performance period start, was smaller than usual, as NAACOS pointed out. We are hopeful for a robust 2020 MSSP class which would continue previous trends of net program growth. In continued efforts to help ACOs take on risk, NAACOS February Bootcamp continues to focus on dealing with risk.
- Direct Contracting Model launches
The Implementation Period of Direct Contracting, the latest accountable care model from the Center for Medicare & Medicaid Innovation, gets underway in 2020. The application process for those interested in the first performance year of 2021 is expected to open this spring as well. NAACOS has launched the Direct Contracting Taskforce to help educate ACOs and others interested in the model, while advocating for positive changes.
- Next Gen ACO Program sunsets; NAACOS calls for certification
This year is the final performance year for the successful Next Generation ACO Model – unless HHS acts to make it permanent Medicare program. NAACOS continues to urge administration officials to certify the CMS Innovation Center model quickly so that ACOs have as many options available on which to base future participation decisions. This is especially true as ACOs weigh Direct Contracting.
- New Medicare payment models continue
CMS spent much of 2019 rolling out several new alternative payment models, including Primary Care First, Emergency Triage, Treat, and Transport (ET3) and two different voluntary kidney care models. The Innovation Center continues to work on a replacement for the Oncology Care Model and a new rural-focused model. Meanwhile, advocating for an overlap policy that at least doesn’t disenfranchise ACOs remains a priority for NAACOS, as CMS continues to work on the issue.
- HHS continues care coordination regulatory work
The “Regulatory Sprint to Coordinated Care” remains a priority for HHS. In 2020, NAACOS is on the lookout for final rules around both fraud and abuse waivers for value-based care and the privacy of substance abuse treatment records, after we commented on proposed rules. HHS may also release a proposed rule updating rules around Health Insurance Portability and Accountability Act, in changes meant to streamline federal regulations to promote care coordination.
- Accountable care models continue expansion beyond Medicare
As ACOs continue to demonstrate success, the model expands its reach beyond Medicare affecting patients and payers across the healthcare industry. Some states in 2020 will continue major Medicaid ACO programs and additional contracting for care delivery models between State Medicaid Managed Care organizations and local ACOs. For commercial payers, accountable care and other value-based payment models have sustained interest.
- MACRA’s Quality Payment Program enters fourth year
NAACOS continues to pay close attention to MACRA’s Quality Payment Program (QPP), which has several areas of interest to ACOs. Last year, CMS discussed aligning the MSSP and the Merit-Based Incentive Payment System (MIPS) quality scoring methodology, which NAACOS pushed strongly against. While the agency did not finalize that change, it has noted it will likely consider it further. Also last year, CMS said it would move ahead with creation of a MIPS Value Pathways, which aims to streamline reporting for certain specialties outside of ACOs.
- Two final health information technology rules pending
The White House is currently reviewing a pair of final rules that aim to make it easier for patients to access and share their medical records. Specifically, a rule from HHS’s health IT office would outline the definition of “information blocking”, which NAACOS commented on last year. CMS is also considering making the sharing of admission, discharge and transfer feeds a condition of participation in Medicare.
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DIRECT CONTRACTING APPLICATION TOOL OPEN
The CMS Innovation Center recently announced it has opened the application portal for the Professional and Global options of the Direct Contracting Model. Those interested in participating in the Implementation Period later this year, which aims to give time to build patient alignment and care coordination networks, must submit an application by February 25. Applications to start in the first performance period in 2021 will be accepted later this spring. CMS recently announced a webinar on January 8 at 2 pm ET to discuss applications and model benefit enhancements, registration is available. More information and resources on Direct Contracting can be found on NAACOS’s dedicated page for the model. Email DirectContracting@naacos.com for any questions or feedback.
CMS UPDATES 2019 QUALITY BENCHMARKS FOR ACO-17, SMOKING CESSATION MEASURE
As a result of NAACOS advocacy, CMS makes ACO-17, the Smoking Cessation quality measure, pay-for-reporting in 2019. CMS has updated the 2019 quality measure benchmarks to reflect changes made to the measure for 2019, as requested by NAACOS. The updated benchmark document is available.
QPP POSTS 2020 QUALITY MEASURE SPECIFICATIONS FOR WEB INTERFACE MEASURES
The QPP recently posted 2020 quality measure specifications and supporting information for Web Interface quality measures on the QPP resource library. ACOs should refer to these specifications for 2020 performance year quality information. Please note these should not be used for reporting 2019 quality measure information.
2019 WEB INTERFACE QUALITY REPORTING BEGINS
The performance year (PY) 2019 quality data submission period for ACOs will take place from January 2, 2020 at 10am EST closing March 31, 2020 at 8pm EDT. ACOs submit quality data using the CMS Web Interface. For ACOs subject to MIPS, CMS also uses this quality data to assess quality performance for that program.
CMS has now delivered a CMS Web Interface Beneficiary Sample Excel file via the Managed File Transfer (MFT) mailbox to each ACO’s quality reporting sample for PY 2019. This file will be available in the MFT mailbox for 30 days from the delivery date. ACOs will need to access this file through the binary directory. If you need additional guidance regarding downloading binary files, please reference the two MFT manuals in the ACO and ACO-OS (ACO-Operational System) Data Exchange User Guide, Version 8 (V8) available in the Resources section of the ACO-MS. Each person associated with an ACO who needs to access the CMS Web Interface in January must have their own Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account with the appropriate role. This will allow the user to download their ACO’s Beneficiary Samples and submit CMS Web Interface data when it opens for reporting on January 2, 2020. Detailed instructions for creating a HARP account and requesting a role are available in the QPP Access User Guide, available in the QPP Resource Library. CMS instructs ACOs to contact the QPP Help Desk with any questions regarding this process at QPP@cms.hhs.gov or 1-866-288-8292. CMS has also posted a demo video.
More information on ACO quality reporting is available in our new ACO Quality Reporting Guide. Additionally, NAACOS will host a one hour webinar on January 16, 2020 from 12:00-1:00 pm Eastern to walk through this new resource and answer ACO questions on the quality reporting process. Register today!
NAACOS COMMENTS ON PROPOSED STARK AND ANTI-KICKBACK RULES
NAACOS recently submitted comments in response to an HHS Office of Inspector General (OIG) proposed rule on the federal anti-kickback statute (AKS) and a CMS proposed rule on the physician self-referral law (Stark). These proposals were released in the fall and aim to ease burdens from these federal fraud and abuse laws. The proposals outline Stark exceptions and AKS safe harbors centered on value-based arrangements, care coordination arrangements and arrangements involving financial risk. The rules also focus on payment arrangements outside the context of fee-for-service Medicare and are part of HHS’s wider effort to transition to value-based care arrangements. NAACOS’s comments provide overall support of these proposals with specific requests including that the agencies ensure certain safeguards and finalize language confirming that these waivers do not supersede those already in place for ACOs.
CURRENT BANKING INFORMATION NEEDED FOR ADVANCED APM BONUSES
CMS is making one final plea for providers to update their banking information to receive the 5 percent bonus as a Qualifying Alternative Payment Model (APM) participant, based on 2017 performance. While many providers have already received these bonuses, in a recent Federal Register notice, CMS says it has made efforts to locate the current banking information, which is necessary to distribute the payments, but the agency has been unable to do so for certain eligible providers. The Federal Register notice includes a list of providers for whom the agency needs accurate banking information. Be sure to work with your ACO’s participant Tax IDs (TINs) to ensure the information on file with CMS is correct so providers don’t miss out on this bonus.
POST PUBLIC REPORTING TEMPLATE BY FEB. 7, 2020
In the last CMS ACO Spotlight Newsletter, CMS notes that the public reporting process will change starting with PY 2020. CMS now will no longer issue a pre-populated public reporting template for ACOs. Instead, ACOs must access a Public Reporting template in the resources section of the ACO Management System (ACO-MS) and use the sample template to populate with your own ACO-specific information. This template will be made available on January 3, 2020 and ACOs must update their public reporting webpages with the PY 2020 information no later than February 7, 2020. |
