NAACOS Newsletter for Members and Partners July 14, 2022

Table of Contents
2023 MPFS Proposed Rule Released
Discounted Early Rate Ends This Friday, Register Now to Save
Our Next DC Learning Discussion Is Tomorrow
Complete Our Brief Survey and Help Inform CMS eCQM Policies
NAACOS Writes CMS on Beneficiary Notification Improvements
Celebrate Medicare’s Anniversary with NAACOS
Aisha Pittman Joins NAACOS as SVP of Government Affairs
House Releases Proposed Health Funding Bill
Congress Leans In To Pre-election Priorities
CMMI Releases ACO REACH Application Decisions
CMS Releases List of Unpaid 2022 Advanced APM Bonuses
CMS Updates QP Status and Data After First Snapshot
CMMI Models Reviewed for Implicit Bias
CMS Publishes Blog on Health Equity Framework
NAACOS Hosting Provider Compensation Call on July 25
ACO Role-based Affinity Groups Have Launched
New Learning Lab on Medicaid at Fall Conference

2023 MPFS PROPOSED RULE RELEASED
The Centers for Medicare & Medicaid Services (CMS) recently released the 2023 Medicare Physician Fee Schedule (MPFS) Proposed Rule. The rule contains many positive proposals for the Medicare Shared Savings Program (MSSP) that NAACOS has long been advocating, including a more appropriate glidepath to risk, more realistic and favorable benchmarking policies, favorable changes to quality scoring, and reduced regulatory burden.

NAACOS Webinars Review Significant MSSP Proposals
NAACOS will host two webinars on the MPFS Proposed Rule. The first webinar will be on July 20 from 1:00–2:30 pm ET and will provide a detailed overview of the proposed policies. Then, on July 28 from 2:00–3:00 pm ET, NAACOS will host a webinar reviewing the proposed changes to financial methodologies. Both webinars are free to members and business partners. Please note that you will need to register separately for each one.

Highlights from the Proposed Rule
A link to the CMS MPFS Factsheet is provided as well as a Quality Payment Program (QPP) Factsheet. If finalized, the proposed rule would:
  • Decrease the Medicare conversion factor from $33.598 to $33.0775 for 2023.
  • Change the current “Pathways to Success” glidepath to allow more time before advancing to risk.
    • Certain ACOs inexperienced with risk would be allowed to participate in the program for up to seven years before advancing to risk
    • The Enhanced Track would be optional for all ACOs
    • ACOs currently participating in Basic Track Level A or B would have the option to elect to continue in their current level of the Basic Track glide path for the remainder of the agreement. Starting July 22, 2022, ACOs can make this election in the ACO-MS beginning July 22, 2022. The deadline to make the election is September 9 at 12:00 pm ET.
  • Establish advance investment payments (AIPs) for certain low revenue ACOs inexperienced with performance-based risk that are eligible to participate in the MSSP Basic Track glidepath. The AIP includes an upfront fixed payment and quarterly payments distributed over two years, which will be based on the number of assigned beneficiaries, capped at 10,000 and adjusted for beneficiaries’ social risk.
  • Make significant changes to the calculation of benchmarks:
    • Incorporate a prospectively projected administrative growth factor into a three-way blend with national and regional growth rates to update an ACO’s historical benchmark for each performance year.
    • Account for changes in ACOs’ demographic risk scores before applying its 3 percent cap on clinical risk scores and apply the cap in aggregate across all four enrollment types.
    • Account for an ACO’s prior savings in rebased benchmarks to help mitigate the lowering of an ACO’s benchmark over time.
    • Reduce the cap on negative regional adjustments from -5 percent to -1.5 percent. After the cap is applied to the regional adjustment, gradually decrease the negative regional adjustment amount as an ACO’s proportion of dual eligible beneficiaries increases or its weighted-average prospective hierarchical condition code (HCC) risk score increases.
    • Move the window used to calculate regional adjustments from the preceding calendar year to an off-set window that matches the assignment window for ACOs that use prospective assignment.
    • Seek comment on alternative approaches to establishing ACO benchmarks using administratively set trends rather than historical spending in order to eliminate the “ratcheting effect.”
  • Allow all low revenue ACOs a chance to share in some savings even if they fail to meet or exceed their minimum savings rate (MSR).
    • Make changes to policies for establishing the quality performance standard threshold used in determining shared savings rates.
    • Extend incentives for reporting electronic clinical quality measures (eCQMs) through 2024.
  • Add health equity quality bonus points for ACOs with high quality performance in highly underserved populations.
  • Reduce burden by:
    • Revising the beneficiary notification requirement from an annual requirement to once per agreement period.
    • Streamlining the three-day skilled nursing facility (SNF) waiver application process.
  • Permanently establish the 8 percent minimum Generally Applicable Nominal Risk standard for Advanced APMs (alternative payment models).
NAACOS staff are currently reviewing the regulation and will provide a detailed analysis to members shortly. Should you have any questions, please email us at advocacy@naacos.com.

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DISCOUNTED EARLY RATE ENDS THIS FRIDAY, REGISTER NOW TO SAVE
Join us September 7–9, 2022, for the NAACOS Fall Conference at the Marriott Marquis Washington, D.C. Register before July 15 for the in-person conference and receive a discount of $300 per person. Can’t attend in person? Register for our live webcast before July 15 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 increase July 15!

CMS Brooks-Lasure Confirmed to Open Conference
CMS Administrator Chiquita Brooks-LaSure is now confirmed to keynote the conference. Ms. Brooks-LaSure oversees programs at CMS including Medicare, Medicaid, the Children’s Health Insurance Program (CHIP), and the HealthCare.gov health insurance marketplace. The agenda will also feature leading ACO experts and CMS officials sharing timely and essential information for ACOs. Full agenda is now available.

Two pre-conference workshops on Wednesday, September 7 from 1:00 pm to 5:00 pm can enrich your conference learning. The two workshops will be focused on:
  • ACO REACH Compliance and Waivers chaired by Beth Patak, Equality Health
  • Preparing for eCQM Reporting chaired by Anna Taylor, MultiCare Connected Care
Exhibitor and sponsor opportunities are now available!
The NAACOS Fall Conference will feature exhibitors with products and services specifically for the accountable care community. Reserve your space today!

OUR NEXT DC LEARNING DISCUSSION IS TOMORROW
NAACOS’ July Direct Contracting (DC) Learning Discussion will take place this Friday, July 15, from 12:00–1:00 pm ET. We will discuss the Center for Medicare and Medicaid Innovation (CMMI) 2023 application decisions for ACO REACH, the Q1 retrospective trend adjustment, and how we are addressing continued opposition to ACO REACH as part of our media campaigns. Participation is limited to those participating in the model in 2022. Accordingly, advanced registration is required. If you have questions or additional topics you want discussed, please share them in advance by emailing directcontracting@naacos.com. Our goal is to make these discussions collaborative and a forum for shared learning.

COMPLETE OUR BRIEF SURVEY AND HELP INFORM CMS ECQM POLICIES
We would like to hear from members regarding the key cost and implementation challenges associated with electronic clinical quality measures (eCQMs) and the revised quality performance standard. Information you share will help NAACOS advocate for fair and appropriate policies to allow ACOs to continue to transition to eCQM reporting without harming the value-based movement. Please take our 5-minute survey, limiting your responses to one per ACO.


NAACOS WRITES CMS ON BENEFICIARY NOTIFICATION IMPROVEMENTS
CMS sought input on improving ACO beneficiary notifications. Last week NAACOS sent CMS recommendations asking the agency to provide flexibility for ACOs to draft their own letter that’s approved by CMS, similar to the approach used for ACOs’ marketing materials. Rather than seeking agreement on one letter that is used by all ACOs, CMS could provide standards and expectations for the beneficiary notification. As ACOs are aware, these notifications cause tremendous confusion among patients. NAACOS wants to work with CMS to establish a process that eliminates confusion and better informs beneficiaries about their care.

CELEBRATE MEDICARE’S ANNIVERSARY WITH NAACOS
July 30, 2022, marks the 57th anniversary of Medicare. NAACOS will be highlighting the importance of value-based care in the program. Specifically, we will showcase that ACOs save Medicare money while delivering high-quality care to beneficiaries, but misinformation has led some to call for the removal of accountable care models from Medicare. Please join us in our social media campaign throughout the month of July. We are encouraging members to use our social media toolkit to share key messages and graphics, use our Take Action page to write your representatives in support of policies that protect and grow ACO models, and draft commentaries/letters to the editor to share this message with your communities. You can download the toolkit today to get started!

AISHA PITTMAN JOINS NAACOS AS SVP OF GOVERNMENT AFFAIRS
NAACOS is pleased to announce that Aisha Pittman will serve as its next senior vice president of government affairs. In her role, Pittman will lead NAACOS’ policy analysis and advocacy work, helping promote legislative and regulatory policies that will advance ACOs. She has 19 years of experience in healthcare payment, alternative payment models, healthcare quality measurement, and health information technology. She started on July 11. Pittman was previously vice president of policy with Premier, Inc. During her eight years there, she was responsible for working with policymakers, providers, and other healthcare stakeholders to reduce costs and improve the quality of health care. Prior to Premier, Pittman held senior management roles with the National Quality Forum, the Maryland Health Care Commission and CenterLight Healthcare, in addition to experience at the National Committee for Quality Assurance. Please welcome Aisha to the NAACOS family at aisha_pittman@naacos.com.


HOUSE RELEASES PROPOSED HEALTH FUNDING BILL
On June 30, the House Appropriations Committee approved the Fiscal Year (FY) 2023 Labor, Health and Human Services (HHS), Education funding bill. The bill provides $4.3 billion for CMS administrative expenses, an increase of $322 million above the FY 2022 enacted level and equal to the President’s budget request. The committee also included $1 million for HHS to establish and maintain a report on best practices of population health management through the creation of a population health task force. It also includes report language asking CMS to address overpayments to Medicare Advantage (MA), along with a request for a report comparing per enrollee spending in MA and fee-for-service Medicare. The House’s HHS funding bill does not represent a bipartisan consensus and is only the first step in the appropriations process. The House and Senate will need to reach a bipartisan agreement in the coming months to extend government funding past the end of the fiscal year that ends on September 30.

CONGRESS LEANS IN TO PRE-ELECTION PRIORITIES
Congress returns this week with Senate Democrats working to finalize agreement on a reconciliation package that has been stalled since last year. Notably, Senate Majority Leader Schumer (D-NY) has tested positive for COVID-19, and Senator Pat Leahy (D-VT) is out for hip surgery, so the Senate does not have the requisite votes to advance the reconciliation package this week. Discussions are centered around a scaled back package that includes drug pricing, tax, and energy reform proposals. Many advocates are also closely watching a health-related provision that has received renewed interest to extend the life of the Medicare Trust Fund through 2031. The provision would require a new nearly 4 percent tax on income from certain pass-through entities such as limited liability partnerships and certain corporate structures, and the “trades,” such as physician practices and law offices. There are also several hearings on the agenda this week where lawmakers will discuss reproductive rights following the Dobbs decision, with the House also planning to hold votes on legislative proposals.

CMMI RELEASES ACO REACH APPLICATION DECISIONS
CMMI recently notified applicants for its revamped ACO REACH Model of their acceptance or denial. According to the fact sheet CMMI received 271 completed applications and accepted 128 of them, a 47 percent acceptance rate. This is both a high number of applications and a much lower than normal acceptance rate. CMMI indicated that all applications that did not pose a material program integrity risk and received a strong application score were accepted. The number of applications accepted does not reflect current Global and Professional Direct Contracting (GPDC) Model participants, who must meet all ACO REACH requirements to continue participating. Next month, CMMI is planning to release the names of participants in the next implementation period. More information is also included in this frequently asked questions document from CMMI.


CMS RELEASES LIST OF UNPAID 2022 ADVANCED APM BONUSES
In June, CMS announced disbursement of the 2022 5 percent Advanced APM bonus to eligible clinicians who were Qualifying APM Participants (QPs) based on their 2020 performance. CMS recently published the list of unpaid QPs to whom the agency has been unable to complete payments. CMS is asking clinicians to verify their information using the 2022 QP Notice for APM Incentive Payment Zip File and complete the 2022 Billing Information Collection Form and submit it to the QPP Help Desk at QualityPaymentProgramAPMHelpdesk@cms.hhs.gov no later than November 1, 2022.

CMS UPDATES QP STATUS AND DATA AFTER FIRST SNAPSHOT
On July 8, CMS updated its QPP Participation Status Tool based on the first snapshot of Advanced APM data. The first snapshot includes data from Medicare Part B claims with dates of service from January 1 through March 31. QP providers must receive at least 50 percent of their Medicare Part B payments or see at least 35 percent of Medicare patients through an Advanced APM entity to be eligible for a 5 percent bonus paid in 2024.

As previously reported in our newsletters, more providers in ACOs and DCEs will be eligible to earn these bonuses as a result of NAACOS’ advocacy to prevent the QP thresholds from sharply rising in 2021. Performance Year 2022 is also the final year for providers to qualify for a 5 percent bonus in payment year 2024. NAACOS and our stakeholder partners are engaging with Congress asking lawmakers to extend these incentives for six additional years. NAACOS is asking our members to contact Congress today to ask them to support an extension of these critical payments for value-based care providers.

CMMI MODELS REVIEWED FOR IMPLICIT BIAS
In support of its efforts to address health equity across all models, CMMI recently conducted a review of three existing payment and delivery models, assessing for the presence of implicit bias and the impacts of any discovered bias. Evaluators found elements of bias within the Kidney Care Choices (KCC) Model, Comprehensive Care for Joint Replacement (CJR) Model, and Million Hearts® Cardiovascular Risk Reduction Model. For example, there was bias in screening and alignment policies for KCC, in CJR selection bias leading to a less medically-complex and less racially-diverse patient mix, and demographic data inaccuracies that led to systemic underestimation of risk for patients from certain racial/ethnic groups and the exclusion of otherwise-eligible Black beneficiaries from the Million Hearts® Model. The model tests for KCC and CJR are ongoing, and the Innovation Center has issued new guidance or revised policies to attempt to mitigate these implicit bias impacts. Additionally, CMMI will be developing a step-by-step guide to screen for and mitigate bias in current and new models.


CMS PUBLISHES BLOG ON HEALTH EQUITY FRAMEWORK
Last week, the CMS Office of Minority Health (OMH) published a blog detailing the development of the CMS Framework for Health Equity released earlier this year. This framework was designed to provide an integrated, action-oriented approach for CMS to advance health equity, including a 10-year plan to embed health equity across all CMS programs. CMS plans to continue to engage with communities affected by disparities to design, implement, and operationalize policies and programs that support health equity. You can learn more about these efforts on the CMS OMH website.

NAACOS HOSTING PROVIDER COMPENSATION CALL ON JULY 25
With much interest recently expressed on the topic of provider compensation modeling, NAACOS has set up a Zoom discussion for our members on July 25 from 3:00–4:00 pm ET. Dr. Rob Fields, Executive Vice President and Chief Population Health Officer, Mt. Sinai Health System, will be discussing Sinai’s approach to this topic. He will provide insight in the ways value-based systems can change incentives to motivate behavior change and drive performance on quality and savings by promoting value-based operations and performance using a risk-adjusted panel size model of productivity. This session will be open to live questions and will provide an opportunity for others to express their experiences in provider compensation. Make sure to add the appointment and Zoom link to your calendar!

ACO ROLE-BASED AFFINITY GROUPS HAVE LAUNCHED
Sign up now to participate in NAACOS Affinity Group Meetings designed to foster peer-to-peer exchange among those with similar professionals roles tackling current ACO and population health issues. These sessions are in addition to the in-person affinity group sessions held at our fall and spring conferences and will be held virtually every few months throughout the year. There are currently five groups categorized by professional role. You may join one or more depending on your current role and responsibilities. You will need to sign up individually for each group that you would like to participate in. Sign up today for your NAACOS Affinity Group series so you don’t miss out on your chance to connect with peers throughout the year! NEW LEARNING LAB ON MEDICAID AT FALL CONFERENCE!
NAACOS will be kicking off a New Learning Lab focused on Medicaid ACOs and Contracts that will take place on September 7, 2022, in conjunction with the Fall conference. This will be a separate event that is free to current NAACOS ACO members. Because there is no fee to register, we are limiting participation to one person per organization. Additional staff may participate in follow up Lab activities held virtually. Those participating in the Specialist Engagement and Incentives Learning Lab will also meet at this time on September 7. Register Today to attend the Medicaid Lab and learn with peers! If a representative from your ACO has expertise to present or would like to take a more active role in either of the learning labs, please reach out to Melody Danko-Holsomback, VP of Education, mdholsomback@naacos.com.