WHAT
TO WATCH IN 2022 The
new year brings opportunities and challenges for ACOs and value-based care
providers, despite lingering effects of the COVID-19 Public Health Emergency (PHE)
and other common themes. The Biden administration will have a second year to
implement its agenda, which includes expanding accountable care. Important issues
confront Congress, which faces November elections and continued work on a large
social spending package. NAACOS is poised to help members learn and adjust to an
ever-changing landscape, and we have drafted the top issues for ACOs to watch in 2022. As always, we
encourage members to contact us with any questions or concerns at advocacy@naacos.com.
NAACOS
Resource Review: Telehealth resources for
2022
As
a new year begins, we want to remind our members of the
resources available to provide guidance for the continued
development of your telehealth programs. A summary of the
updates in the Final Medicare Physician Fee Schedule (PFS) Rule
for telehealth can be found on this CMS Fact Sheet. Additionally, there are
resources for telehealth visit and billing requirements related
to COVID-19 PHE flexibilities on the NAACOS Telehealth and COVID-19 page. This includes a link to
the CMS Current Emergencies webpage
containing numerous up-to-date links to the current PHE policies
and toolkits. The CMS emergencies page contains a nursing home telehealth toolkit for long
term care nursing homes visits, which has been a recent topic of
interest among NAACOS member leading to a webinar on annual wellness visits.
2022
QUALITY MEASURE INFORMATION NOW AVAILABLE CMS
has released 2022 quality measure information. This includes both Web Interface and Merit-Based Incentive Payment System
(MIPS) clinical quality measure information and supporting
documents. In addition, the Quality Payment Program (QPP) resource
library includes an alternative payment model (APM) Performance Pathway
(APP) toolkit providing an overview of quality requirements for the APP. NAACOS has
created a resource to outline key APP information for ACOs
specifically, including quality requirements for ACOs in 2021 through 2025 under the
new APP policies.
CONGRESS
MULLS RULE CHANGES WHILE BBB STALLS Negotiations
concerning the Build Back Better (BBB) spending legislation have stalled following
news that Sen. Joe Manchin (D-WV) will not support the package. In a further sign
that the legislation is on the back burner for now, the Senate parliamentarian has
ceased to continue its “Byrd Bath” review of the legislation, pending further
developments. Provisions concerning drug pricing and other health related matters
may advance later this year as more limited bills. This week Congress turns to
voting rights legislation, including a push by the White House and Majority
leadership to alter Senate rules—namely, the filibuster—to allow a vote on the
matter. At the same time, pressure is increasing for House appropriators to act on
government funding, and Democrat Appropriations leadership has scheduled a number of
hearings this week to underscore the impact of federal funding on the federal
government’s ability to respond to the ongoing coronavirus surge, defense, and
national security matters. Lastly, Rep. Pramila Jayapal (D-WA), Chair of the
Progressive Caucus, led a letter with more than 50 lawmakers calling for the
Biden administration to cancel the Direct Contracting Model. NAACOS responded with a letter in support of the model and is
engaged on this and other issues on Capitol Hill as we work to advance our priority
items for 2022.
Welcome
New Business Partners
Access
Telehealth Access
Telehealth offers remote patient care programs that include
innovative remote patient monitoring devices, software, and clinical
monitoring services that can help practices, clinics, and health
systems fully implement transformative chronic care and disease
management programs. accessrpm.com
REGISTER
FOR NAACOS’S HEALTH CARE VALUE WEEK WEBINAR NAACOS
invites all members and business partners to tune into an exciting webinar we have
planned for January 25 in conjunction with Health Care Value Week. This
is a weeklong series of virtual events meant to raise awareness to issues facing
value-based care, including polices needed to advance their work. Registration is
free for all events, and we encourage NAACOS members to attend.
The
NAACOS-sponsored event, entitled How ACOs Improve Patient Outcomes: Lessons Learned
After a Decade of Clinical Transformation, will examine the care-improvement
processes and clinical practices that have been employed by three of the most
successful ACOs. Speakers from Privia Health, Advocate Aurora Health, and Baylor
Scott & White Quality Alliance will share how they work to improve quality while
lowering cost of care over time. Register now!
NAACOS
RESOURCE ON MEDICARE PAYMENT UPDATES UNDER MACRA This
week, NAACOS published a new resource outlining Medicare payment updates under the
Medicare and CHIP Reauthorization Act of 2015 (MACRA) for Performance Years (PY)
2017 through 2024. Importantly, this document highlights the expiration of the 5
percent advanced APM bonus incentive payment, which is only eligible to be earned
through PY 2022, to be paid in payment year 2024. However, the additional 0.5
percent annual payment update for Advanced APMs does not go into effect until PY
2024 for payment year 2026, leaving a gap year in PY 2023 in which there is less
incentive for providers to participate in an Advanced APM. This is not reflective of
the intent of MACRA, which was designed to increase provider participation in
value-based payment models. The Value Act aims to resolve this issue by extending the
Advanced APM bonus, as well as implementing other favorable policy changes to
bolster the Medicare Shared Savings Program (MSSP). We encourage you to visit our Take Action page
to write your representative and urge them to extend the Advanced APM bonus. For
more information on MACRA, NAACOS’ website
includes internal and external resources, including the updated 2022 ACO
Guide to MACRA.
JANUARY’S
DIRECT CONTRACTING LEARNING DISCUSSION NOW SCHEDULED NAACOS
is holding its first Direct Contracting Learning Discussion of the year on January
21. As in 2021, these monthly events are meant for DCEs to share feedback,
questions, concerns, and points of interest. Unlike last year, we are limiting
participation to those participating in the model in 2022. As such, advanced registration is required.
If you have
questions or topics of conversation you want discussed, please send them to directcontracting@naacos.com.
The point is to make these collaborative discussions and a forum for shared
learning. We ask that you come prepared to share your questions, perspectives, and
react to issues at hand.
2021
QUALITY REPORTING UNDERWAY CMS
recently announced the MSSP quality reporting submission period will be open from
January 3, 2022, to March 31, 2022. As a reminder, 2021 is the first year the 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.
Welcome
New Multi-ACO Member
Alignment
Healthcare Raleigh,
NC
NAACOS
SPRING 2022 CONFERENCE TOPICS ANNOUNCED ACOs,
DCEs, and other models focusing on population health can create a future where
quality is better, costs are lower, and patients are engaged. Join us
in Baltimore, April 28–29, and hear from leading accountable care
experts and CMS officials sharing timely and essential information for ACOs and
DCEs. Optional half-day workshops on April 27 will provide in-depth tutorials on
addressing key issues for ACOs and DCEs. The conference will feature sessions
focusing on:
Critical Policy Update for ACOs and DCEs
Increasing Health Equity
Quality Management Across Contracts
Using Data in Benchmarking
Clinical Transformation Through Data
Incorporating Episode Payment Inside Total Cost of Care Models
Digital Care Including Remote Monitoring
Effective Contracting Strategies with SNFs
Understanding Direct Contracting Compliance & Operations
Best Practices with Annual Wellness Visits
The
conference will also include our peer-to-peer exchanges, and our popular CMS
Townhall will close out our conference. Full agenda will be announced soon!
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. 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! Proof of
vaccination required to attend in-person.
Exhibitors
The NAACOS Spring 2022 Conference will feature exhibitors with products
and services specifically for the accountable care community. NAACOS
Partners are the only non-ACOs allowed to attend, exhibit and sponsor
NAACOS conferences. Reserve your space today!
SEND
YOUR SUBMISSIONS FOR LEADERS IN QUALITY EXCELLENCE 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.
NAACOS ACO member organizations can submit an entry for a quality project through
February 4, 2022. NAACOS will recognize the top three submissions,
selected by the NAACOS Quality Committee, at our Spring 2022 Conference
to showcase the exemplary efforts in quality improvement among our
members and to disseminate best practices. More information on the award criteria and submissions process are
available. Should you have any questions, please contact us at advocacy@naacos.com.
CMS
UPDATES QPP STATUS TOOL TO INCLUDE THIRD 2021 SNAPSHOT CMS
recently updated the QPP
participation status tool to reflect the third snapshot period
for PY 2021 evaluation for meeting Advanced APM thresholds, known as
Qualifying APM Participant (QP) thresholds. Meeting or exceeding those
thresholds is required to earn the annual Advanced APM bonus for PY
2021, which will be paid in 2023. The update also reflects APM status
for MIPS.
This snapshot period focused on January 1 through
August 31, 2021. Importantly, many more ACOs and providers are eligible
to earn Advanced APM bonuses as a result of NAACOS’s advocacy to prevent the QP thresholds
from rising in 2021 and 2022 as they were previously scheduled to before
Congress changed them. To learn more about these bonuses, QP thresholds,
and how to qualify, please refer to NAACOS’s resource, The ACO Guide to MACRA.
CMS
PUBLISHES PROPOSED CHANGES TO MEDICARE ADVANTAGE PLANS CMS
earlier this month published a proposed rule that makes updates for providers
of both Medicare Advantage and Part D prescription drug benefit plans.
Among the changes proposed are greater standards for proving that MA
plans offer an adequate network of providers and more transparency in
medical-loss ratio reporting. There was nothing noteworthy that directly
relates to ACOs and value-based care entities in traditional Medicare. A
final rule is expected this spring and will take effect in 2023. More
information can be found in the CMS fact sheet. NAACOS will watch for additional
changes in the upcoming annual call letter.
CMS
PROPOSED LIMITED COVERAGE OF NEW ALZHEIMER’S DRUG Following
NAACOS advocacy, CMS announced this week that it would only cover a
controversial new Alzheimer’s drug for patients enrolled in clinical trials
that further study the drug’s effectiveness. The process is called “coverage
with evidence development.” NAACOS wrote CMS last summer with a similar request
for limited coverage, following its approval. The drug in question, Aduhelm,
would be covered under Part B and counted as ACO expenditures, but many have
questioned its clinical benefit. The annual price of the drug was recently
cut in half to $28,000, which is still almost three times the average annual
spending on a Medicare beneficiary. This week’s decision is only preliminary, and a
final coverage policy is due in April.
KIDNEY
CARE CHOICES MODEL PARTICIPANTS ANNOUNCED CMS
has named 30 practices participating in Kidney Care
First and 55 organizations in Comprehensive Kidney Care Contracting (CKCC),
both of which kicked off this month. CKCC is the kidney care-specific
alternative to Global and Professional Direct Contracting. Seven of the
kidney contracting entities have selected the Global Option, 37 have
selected the Professional Option, and 11 have selected the Graduated Option
(Level 1 or Level 2). More information on the Kidney Care Choices Model is
in this NAACOS resource.
NAACOS is closely
watching for CMS to announce new classes of participants in other
alternative payment models, including MSSP and Global and Professional
Direct Contracting. We will alert members when those announcements are
made.