NAACOS Newsletter for Members and Partners July 18, 2024

Nominate Your Organization for an Excellence Award
NAACOS ADVOCACY
CMS Proposes to Address Suspected DME Fraud
New Resource and Upcoming Webinar on Patient Engagement in ACOs
NAACOS Members Testify at Congressional Hearing
NAACOS Provides Feedback on Primary Care Legislation
NAACOS and Others Support Rural Providers in APMs

CONGRESSIONAL UPDATES
Lawmakers Send Letter Supporting Accountable Care Models

ADMINISTRATION UPDATES
MSSP Application Phase 1 RFI-1 Open to August 1
PC Flex Application Questionnaire Due August 1
2023 MIPS Final Score Previews Posted
CMS Posts Updates for Qualifying APM Participants
Evaluations Released for Direct Contracting, Vermont Model
CMS Announces Participants in AHEAD, GUIDE Models
CMS Proposes Updates to Hospital Outpatient Payments
ONC Releases HIT-2 Proposed Rule

EDUCATION OPPORTUNITIES
Fall Conference Agenda Now Available
NAACOS Announces Webinar on MPFS
Register for July Practice Transformation Learning Lab
IAC Analyzes Impact of TEAM on ACO Hospitals

WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE



NOMINATE YOUR ORGANIZATION FOR AN EXCELLENCE AWARD
The call for submissions is now open for the 2024 NAACOS Excellence Awards. The NAACOS Excellence Awards recognize high-performing organizations that have demonstrated an outstanding commitment to and accomplishments in value-based care. Recipients of the award exemplify how value-based care can transform health care delivery by improving quality and outcomes, lowering or slowing growth of costs, and increasing patient and provider satisfaction. Submissions will need to demonstrate success in five key areas: patient and community engagement, commitment to a value culture across the organization, a focus on outcomes and use of data and tools, and how clinical interventions are used to improve patient care. The call for submissions will close on August 2.

Awardees will be notified in early September, and awards will be presented during the plenary session at the NAACOS Fall Conference October 17–18 at the Marriot Marquis in Washington, D.C. Awardees will also present as part of a panel discussion. Presenters will be given complimentary conference registration. Learn more about the award criteria and submission process on our website; submit your entry today! If you have any questions, email advocacy@naacos.com.


NAACOS ADVOCACY


CMS PROPOSES TO ADDRESS SUSPECTED DME FRAUD
CMS issued a proposed rule to address anomalous billings for catheters in Medicare ACOs that would remove claims from two problematic catheter codes from MSSP’s Performance Year (PY) 2023 expenditures, including the national-regional blended update factor used to update the benchmarks for all ACOs. Reconciliation for 2023 is expected to be delayed by six weeks, and historical benchmarks for ACOs starting new agreements this year will be delayed. The CMS Innovation Center intends to take similar measures for the ACO REACH model. Comments are due July 29; please review NAACOS draft comments and send any feedback to David Pittman.

Contact the Institute for Accountable Care (IAC) as we can provide data to help you determine how the new policy will affect your 2023 benchmark update factor for a fee.

In addition, CMS proposed a permanent approach to address significant anomalous and highly suspect billing in the Medicare Physician Fee Schedule proposed rule. Across both rules, CMS implemented recommendations from NAACOS and other stakeholders.

NEW RESOURCE AND UPCOMING WEBINAR ON PATIENT ENGAGEMENT IN ACOS
Today, NAACOS and the Health Care Transformation Task Force (HCTTF) published joint recommendations for improving beneficiary engagement in accountable care models. Join us on July 31 from 2:00 to 3:00 pm ET for a webinar discussion of the recommendations and their development. Earlier this year, NAACOS and HCTTF convened a cross section of our memberships, including ACOs and patient and consumer advocacy organizations, to discuss Medicare ACO program policies and develop solutions to strengthen patient communication and engagement efforts in Medicare ACOs. The resulting resource, Reimagining Beneficiary Engagement in Accountable Care Models, is available now. During the webinar, speakers Tori Bratcher, President of Integrated Care at Trinity Health, Sarah Coombs, Director for Health System Transformation at the National Partnership for Women & Families, Jeff Micklos, Executive Director at HCTTF, and Aisha Pittman, Senior Vice President of Government Affairs at NAACOS will present the recommendations and discuss the perspectives and aligned priorities of consumer advocates and ACOs.Register today!

NAACOS MEMBERS TESTIFY AT CONGRESSIONAL HEARING
In case you missed it, last month NAACOS members Coastal Carolina Quality Care, Main Street Health, and Duly Health and Care testified at a House Ways and Means Health Subcommittee hearing to discuss value-based care. NAACOS is excited that this issue is gathering more interest from Congress.
  • Earlier this summer, we responded to a request for information from the Senate Finance Committee’s White Paper on Medicare Physician Payment and Chronic Care.
  • NAACOS and our partners in the Alliance for Value-Based Care also coordinated a stakeholder letter providing recommendations to lawmakers on how to improve Medicare’s payment system and promote the transition to APMs.
NAACOS PROVIDES FEEDBACK ON PRIMARY CARE LEGISLATION
Senators Sheldon Whitehouse (D-RI) and Bill Cassidy (R-LA) introduced legislation to expand hybrid primary care payments in Medicare. In a comment letter, NAACOS expressed support for expanding hybrid primary care payments to more clinicians in Medicare models where providers are held accountable for total cost of care and quality, such as MSSP, ACO REACH, and future CMS Innovation Center models.

NAACOS AND OTHERS SUPPORT RURAL PROVIDERS IN APMS
NAACOS joined 11 other organizations in recommending ways to expand alternative payment models (APMs) in rural communities. The letter to CMS leaders asks for more flexibility and rural-specific tracks, among other things. It also asks that CMS reconsider the focus of models for rural providers, shifting from reducing costs to maintaining access or improving quality. This letter includes similar recommendations as a letter NAACOS sent last year.


CONGRESSIONAL UPDATES

LAWMAKERS SEND LETTER SUPPORTING ACCOUNTABLE CARE MODELS
Rep. Darin LaHood (R-IL), Rep. Kim Schrier (D-WA) and 12 colleagues sent a bipartisan letter to CMS expressing support for alternative payment models and ACOs. The letter highlights the success of the CMS Innovation Center’s ACO models and encourages the administration to continue building and expanding these models.
ADMINISTRATION UPDATES

MSSP APPLICATION PHASE 1 RFI-1 OPEN TO AUGUST 1
MSSP ACOs applying to participate or submitting change requests for PY 2025 have until 12:00 pm ET on August 1 to respond to the Phase 1 RFI-1. This deadline is the final opportunity to add ACO participant TINs to your roster for PY 2025. This is also the final opportunity to elect to apply for a SNF 3-Day Rule waiver and add SNF affiliate TINs. More information is available on the MSSP Application Types & Timeline webpage and in the Application Toolkit, which includes detailed guidance documents and sample applications.

PC FLEX APPLICATION QUESTIONNAIRE DUE AUGUST 1
ACOs applying to participate in the ACO Primary Care Flex (PC Flex) Model, which launches January 1, 2025, must submit a supplemental ACO PC Flex application questionnaire by August 1, 2024. Details on the questionnaire are available in the PC Flex request for applications (RFA). ACOs must have submitted the MSSP Phase 1 application by the June 17 deadline to submit the PC Flex application questionnaire. Last week a NAACOS Discovery Call covered details in the RFA and changes to the model that NAACOS is advocating for. The recording and slides are available. Additional information is available on the updated FAQs page.

2023 MIPS FINAL SCORE PREVIEWS POSTED
CMS recently posted the PY 2023 Merit-based Incentive Payment System (MIPS) Final Scores on the Quality Payment Program (QPP) website. The final score preview period allows APM entities to preview their final MIPS scores until payment adjustments are released with final performance feedback in August. 2023 scores determine 2025 MIPS payment adjustments. During this time, ACOs can view final scores, performance category level scores and weights, measure level performance, and whether bonus points were earned. MSSP ACOs can access the data by having the QPP Security Official sign in to the QPP website using your ACO Management System (ACO MS) login information. If you feel there is an error with your score, contact the QPP Help Desk at QPP@cms.hhs.gov or call 1-866-288-8292.

CMS POSTS UPDATES FOR QUALIFYING APM PARTICIPANTS
APM Snapshot—On July 15, CMS updated its QPP Participation Status Tool based on the first snapshot of APM data. The first snapshot includes data from Medicare Part B claims with dates of service between January 1, 2024, and March 31, 2024.

APM Non-Payments—CMS began making APM incentive payments in June. The agency also published a list of clinicians who earned APM incentive payments for PY 2022 that CMS does not have current information needed to disburse the payment. If you have any questions concerning submission of information through the QPP website, please contact the QPP Help Desk at 1-866-288-8292. All information must be received by September 1, 2024.

EVALUATIONS RELEASED FOR DIRECT CONTRACTING, VERMONT MODEL
The CMS Innovation Center recently published evaluations for two ACO models. CMS ANNOUNCES PARTICIPANTS IN AHEAD, GUIDE MODELS
CMS PROPOSES UPDATES TO HOSPITAL OUTPATIENT PAYMENTS
On July 10, CMS released the Calendar Year (CY) 2025 Hospital Outpatient Prospective Payment System (OPPS) and ASC Payment System Proposed Rule. CMS is proposing to update OPPS and ASC payments by 2.6 percent. A fact sheet and press release are available. Comments are due by September 9, 2024.

ONC RELEASES HIT-2 PROPOSED RULE
The Office of the National Coordinator for Health Information Technology (ONC) recently released a proposed interoperability rule, Patient Engagement, Information Sharing and Public Health Interoperability (HTI-2). The rule is a continuation of ONC’s efforts to advance interoperability and data sharing and focuses on public health. More information including webinars and fact sheets are available.


EDUCATION OPPORTUNITIES

FALL CONFERENCE AGENDA NOW AVAILABLE
Join us in Washington, D.C., October 16–18 at the Marriott Marquis for the Fall 2024 Conference. The agenda will feature leading value-based care experts and CMS officials sharing timely and essential information for ACOs.

Register before August 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 August 4 and receive a discount of $100 per person. We are offering group rates for both the in-person and virtual conference. Group rates are only available to NAACOS member ACOs. For more information, please contact Emily Perron.

Sponsorship and exhibiting opportunities for the Fall 2024 Conference are selling out! Partners interested in exhibiting or sponsoring should contact Emily Perron.

NAACOS ANNOUNCES WEBINAR ON PROPOSED MPFS
Don’t miss our upcoming webinar on July 24 from 2:00 to 3:15 pm ET reviewing key details of the newly proposed 2025 Medicare Physician Fee Schedule (MPFS) rule. This rule includes policy proposals that affect value-based care and MSSP, including addressing anomalous billing, taking additional steps on creating a higher risk track in MSSP, and other program enhancements such as:
  • Adding a Health Equity Benchmark Adjustment
  • Creating a prepaid shared savings option
  • Making updates to beneficiary notifications
  • Updating quality requirements for ACOs
The webinar will also review proposed changes to physician payment relevant to ACOs, including new billable codes for advanced primary care management services. More information on the rule will be shared through our analysis to be released shortly.

REGISTER FOR JULY PRACTICE TRANSFORMATION LEARNING LAB
On July 26 from 12:00 pm to 1:30 pm ET, NAACOS continues the Practice Transformation Learning Lab series, taking a deeper dive into implementing transformational changes in your ACO participant’s daily work. The July session will include presentations by Brandy Golden, VP Operations Development & Deployment, Vytalize Health, and Jessica Martensen, Vice President of Population Care Management Programs, Essentia Health. Last month we learned how to assess practice readiness for value based contracting and how to choose the level of risk that a participant may be ready to take on. During this month’s meeting, presenters will discuss how they work with practices to make the necessary changes to support value-based care initiatives. These include implementing care management and other patient and provider support systems, documentation, and communication tools. These 90-minute monthly sessions occur on the Fourth Friday of each month from 12:00 pm to 1:30 pm ET. A complete list of topics for future sessions is on the Learning Lab webpage. Be sure not to miss any of the upcoming meetings by registering today to receive the link for the monthly calls that run through May 2025.

IAC ANALYZES IMPACT OF TEAM ON ACO HOSPITALS
The new Transforming Episode Accountability Model (TEAM) will require hospitals in selected markets to assume financial responsibility for five 30-day surgical episodes starting in 2026. Analysis by the Institute for Accountable Care (IAC) indicates that one in five hospitals will lose at least $2,000 per case under TEAM if they cannot reduce episode spending. Using 100 percent of 2023 Medicare claims data, IAC has developed comprehensive benchmarking reports to help hospitals to prepare for success in TEAM. Learn more or contact us..


WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE