NAACOS Newsletter for Members and Partners June 30, 2022

Table of Contents
ACO Role-based Affinity Groups Begin Meeting in July!
ACO REACH Model Wins Backing of Mayors
2023 Board Election Nominations Due by August 5
CMMI Releases Successor to Oncology Care Model
Dr. Asaf Bitton to Keynote Fall Conference
Dobbs Decision Roils Congress
CMS Blog Discusses Specialty Integration in Population Health
NAACOS Cosponsors Webinar with PCC on MSSP Success
NAACOS Submits Comments for MA Oversight Hearing
NAACOS Updates Medicaid ACOs Page
Multiple SCOTUS Opinions Issued on Health Care
NAACOS Launches Social Media Campaign for Medicare Anniversary
CMS Releases Proposed Home Health and ESRD Rules
MedPAC Sends June 2022 Report to Congress
NAACOS Endorses Legislation on Quality Measure Funding
CMS Posts 2021 MIPS Score Previews
CMS Outlines Business Case for Addressing Health-Related Social Needs
Healthy Futures Task Force Releases Plan on Doctor-Patient Relationship
CMS Begins Paying 2020 Advanced APM Bonus

ACO ROLE-BASED AFFINITY GROUPS BEGIN MEETINGS IN JULY!
Sign up now to participate in NAACOS Affinity Group meetings that will foster peer-to-peer exchange of current ACO and population health issues. In addition to the in-person affinity group sessions to be held at our fall and spring conferences, NAACOS will also be offering virtual sessions every few months throughout the year for our members to connect more frequently with peers. There are currently five groups categorized by ACO role. You may join one or more depending on your current roles and responsibilities. You will need to sign up individually for each group that you would like to participate in. Sign up below for your NAACOS Affinity Group series!
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ACO REACH MODEL WINS BACKING OF MAYORS
Earlier this month, the African American Mayors Association passed a resolution encouraging Congress and the Biden administration to continue to support the ACO REACH Model in order to better support value-based care and quality improvement in Medicare. Previously this month, the U.S. Conference of Mayors passed a resolution in support of ACO REACH. The resolutions come as progressive Democrats in Congress continue to put pressure on the Biden administration to terminate the model. NAACOS continues to stress the importance of preserving the model to congressional offices and encourages our ACO members to do so using our Take Action page.

2023 BOARD ELECTION NOMINATIONS DUE BY AUGUST 5
NAACOS is soliciting nominations for its 2023 Board Member Election, which will open in August. The NAACOS Board of Directors’ purpose is to advance the core mission of NAACOS, which focuses on fostering the growth of the ACO model of care. Board members represent a diverse range of ACO interests and help shape NAACOS priorities, such as supporting ACOs in operational and clinical best practices, advocating on behalf of ACOs with Congress and the Executive Branch, and educating the public about the value of accountable care. To be a NAACOS Board Member, candidates must be employed as executives of NAACOS member ACOs in good standing at all times during the term of office. Please nominate a candidate for the board. Information needed is contact information, a two-to-three paragraph description from the nominee, a bio and two letters of recommendation. The bio and letters of recommendation must be attached as files. You will need all of these pieces of information to submit the form. Self-nominations are permitted. If you have any questions, please contact Anna LaFayette.

CMMI RELEASES SUCCESSOR TO ONCOLOGY CARE MODEL
This week, the new Enhancing Oncology Model was announced by the Center for Medicare and Medicaid Innovation (CMMI) and will launch July 2023, replacing the Oncology Care Model (OCM) that sunsets at the end of this month. Unlike OCM, the new five-year model will require downside risk for all participants, offering two levels of risk, place more emphasis on health equity with a requirement that participants screen for health-relate social needs, offer an additional $30 per month for patients dually eligible for Medicare and Medicaid, and require patients electronically report updates on their status and outcomes.

Like the OCM, the Enhancing Oncology Model will be multi-payer and offer participants both a prospective, per-patient bunded payment for triggered episodes and an opportunity for retrospective performance-based payments based on quality and savings. Participants will be responsible for patients’ total cost of care during a six-month episode. However, the monthly prospective payments under the new model are nearly half of OCM — $70 compared to $160. CMS will set different benchmarks for each of the seven cancer types included in the new Enhancing Oncology Model.

The new model is being billed by the Biden-Harris administration as a reignited effort of the Cancer Moonshot. More information can be found on CMS’s fact sheet, request for applications, and frequently asked questions document. Dual participation in the Enhancing Oncology Model is allowed with MSSP and certain other CMMI models. Applications are due by September 30.


DR. ASAF BITTON TO KEYNOTE FALL CONFERENCE
Join us September 7–9, 2022, for the NAACOS Fall Conference at the Marriott Marquis in Washington, D.C. The agenda will feature leading ACO experts and CMS officials sharing timely and essential information for ACOs. Our day one lunch plenary, which will focus on primary care transformation, will feature Asaf Bitton, executive director of Ariadne Labs, a health systems innovation center at Brigham and Women’s Hospital and the Harvard T.H. Chan School of Public Health. Breakout topics and chairs have also been added to our agenda page.

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:
  • ACO REACH Compliance and Waivers chaired by Beth Patak, Equality Health
  • Preparing for eCQM Reporting chaired by Anna Taylor, MultiCare Connected Care
Register Early and Save!
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.

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!

DOBBS DECISION ROILS CONGRESS
In the wake of the Supreme Court of the Unites States (SCOTUS) decision in the Dobbs v. Jackson Women’s Health Organization case on June 24, Democratic lawmakers are asking majority leadership and the Biden administration to take decisive action to protect access to reproductive health care in states that may preclude it via state law. Over the weekend, nearly three dozen Democratic lawmakers wrote to President Biden asking for “bold action.” Senators Warren (D-WA) and Smith (D-MN) called on President Biden to declare a public health emergency (PHE) to extend reproductive rights at the federal level, and the senators relaunched calls to rescind the filibuster to allow a simple majority vote on federal legislation. On June 27, Secretaries Becerra, Yellen, and Walsh wrote to health insurers reminding them of legal requirements to cover contraception at no cost. Meanwhile, bipartisan advocates for telehealth began reviewing what federal and state rules may affect telehealth-assisted pregnancy terminations via medication and the implications for now-pending federal legislation to relax telehealth prescribing and reimbursement requirements post COVID-19 PHE. On the same day that SCOTUS overturned Roe v. Wade via the Dobbs decision, bipartisan lawmakers passed gun control and mental health legislation, freeing up the legislative docket for appropriations work and potential activity on a slimmed-down version of the President’s Build Back Better (BBB) proposal. It is unclear what path Congress will take given the immediacy of the Dobbs decision and whether Congress will pivot back to work on BBB or engage in hearings, oversight investigations, and other activities related to Dobbs. As NAACOS looks towards the year-end funding bill as a potential vehicle for activity on the Advanced APM (Alternative Payment Model) bonus extension, the prospect of a continuing resolution due to a divided and partisan Congress post-Dobbs is something NAACOS is watching closely.

CMS BLOG DISCUSSES SPECIALTY INTEGRATION IN POPULATION HEALTH MODELS
CMS recently published a blog article discussing how best to integrate specialty care in population-based models. These recommendations come after CMS held numerous stakeholder listening sessions on the topic, including one with NAACOS. Importantly, the article discusses the importance of aligning incentives between specialists and ACO initiatives and recognizes the need for CMS to ensure population health incentives are not weakened where there is overlap. Additionally, the blog emphasizes the need for providing data on specialist performance and enhancing data sharing across practices to better facilitate this integration. NAACOS has urged CMS to ensure the agency develops specialty models and overlap policies that do not harm population health models like ACOs. CMS notes an increase in the volume of specialty visits for Medicare patients, as well as spending for these services, underscores the need for effective coordination of primary and specialty care providers.


NAACOS COSPONSORS WEBINAR WITH PCC ON MSSP SUCCESS
This week, NAACOS cosponsored a webinar with the Primary Care Collaborative (PCC) to discuss primary care strategies that have contributed to success in the MSSP. Moderated by Linda Brady, Value-Based Care Portfolio and Network Strategy Manager with Boeing Healthcare Strategy and Well Being, panelists included Dr. Jose Pena, CEO and CMO of RGV ACO Health Providers, Dr. Sarah Mullins, Regional Medical Director with Aledade, and Dr. Fred Wallisch, Medical Director of ACO Programs with Caravan Health. Each of these speakers has a background in primary care and deep knowledge of primary care’s contributions to successful ACOs. This webinar was a follow-up to a previous event examining evidence from MSSP ACOs and exploring the role of primary care in successful ACO models. The recording and slides are available. This event is part of the Better Health Now (BHN) campaign, which is focused on driving policy changes to increase investment in primary care and promote primary care payment models that ensure all communities have access to care.

NAACOS SUBMITS COMMENTS FOR MA OVERSIGHT HEARING
On June 28, the House Energy and Commerce Oversight and Investigations Subcommittee held an oversight hearing of private sector Medicare Advantage (MA) plans. The hearing featured witnesses from the Health and Human Services (HHS) Office of the Inspector General (OIG), Government Accountability Office (GAO), and Medicare Payment Advisory Commission (MedPAC). The hearing examined the quality of care that America’s seniors receive through MA and the fiscal sustainability of the program going forward. NAACOS submitted comments to the committee highlighting how ACOs are an alternative to MA that have a history of lowering costs and improving quality. It also calls on the committee to consider the Value in Health Care Act (H.R. 4587) this year to improve the ACO program and extend the 5 percent Advanced APM bonus. Visit NAACOS Take Action to write your lawmakers today to ask them to support the bill!

NAACOS UPDATES MEDICAID ACOS PAGE
Last week, NAACOS updated the Medicaid ACOs page with key details on state Medicaid programs that have implemented or tested ACO or ACO-like initiatives to serve Medicaid beneficiaries. Given the considerable variability across states in their Medicaid payment models, accountable care initiatives in Medicaid programs often look different from traditional Medicare ACO programs. This webpage includes links to summaries and key resources for each state Medicaid ACO program, with results when available. Importantly, many state Medicaid ACO models focus on addressing social drivers of health (SDOH) as a key strategy to improve outcomes for Medicaid beneficiaries. The new webpage includes several resources on addressing SDOH within ACO models and broadly through Medicaid initiatives. The Medicaid ACO landscape is frequently changing and NAACOS will update this webpage as new resources become available. If you do not see your state included on the page and wish to inform us of Medicaid ACO efforts or programs in your state, please contact us at advocacy@naacos.com.

MULTIPLE SCOTUS OPINIONS ISSUED ON HEALTH CARE
While most of the attention around the Supreme Court went to its abortion-related decisions this week (see above article on the Dobbs decision), there were several other notable moves for the healthcare industry. The nation’s highest court ruled that employer-sponsored health plans can make all dialysis providers out-of-network, making their care so expensive that they potentially drop their employer’s plan and opt for Medicare, which end-stage renal disease (ESRD) patients are eligible for. Justices said intent matters when ruling that prosecutors must prove doctors knowingly prescribed drugs in aberrant ways when trying to punish doctors for prescribing drugs unlawfully. The matter relates to “pill mills” and the opioid epidemic. Lastly, the court ruled against hospitals over how CMS computes Medicare’s disproportionate share hospital adjustments, which is meant to reflect the steeper cost of care for low-income patients. Hospitals had questioned the inclusion of certain Medicare patients.

The Supreme Court declined to hear arguments in a case that MA plans payback payments based on unsupported diagnoses based on a 2014 CMS rule. Also, justices declined to take up a case debating whether a pharmacy benefit manager has a fiduciary responsibility to lower drug prices.


NAACOS LAUNCHES SOCIAL MEDIA CAMPAIGN FOR MEDICARE ANNIVERSARY
This week, NAACOS is launching a social media campaign to spotlight the 57-year anniversary of Medicare, which was signed into law by President Lyndon Johnson on July 30, 1965. The population of beneficiaries served by Medicare has more than tripled in the past five decades and Medicare spending has grown even more significantly. Earlier this year, the 2022 Medicare Trustees Report projected that the Part A Hospital Insurance Fund will be insolvent by 2028. We know value-based care models like ACOs save Medicare money while delivering high-quality care to beneficiaries, which is why we’re encouraging our members to use their social media channels to highlight the importance of ACO models in preserving the longevity of Medicare. NAACOS has developed a social media toolkit with hashtags, draft posts for social media, helpful graphics, and key messaging points for members to use to spread support for ACOs and value in health care. You can download the toolkit and share these messages or edit them to include your own success stories.

CMS RELEASES PROPOSED HOME HEALTH AND ESRD RULES
On June 17, CMS issued the calendar year (CY) 2023 Home Health Prospective Payment System proposed rule, which would update Medicare payment policies and rates for home health agencies (HHAs). CMS estimates that Medicare payments to HHAs in CY 2023 would decrease in the aggregate by -4.2 percent, or -$810 million compared to CY 2022. The fact sheet and proposed rule are available. On June 21, CMS issued a proposed rule to update payment rates and policies under the ESRD Prospective Payment System for renal dialysis services. For hospital-based ESRD facilities, CMS projects an increase in total payments of 3.7 percent. For freestanding facilities, CMS projects an increase in total payments of 3.1 percent. The fact sheet and proposed rule are available.

MEDPAC SENDS JUNE 2022 REPORT TO CONGRESS
On June 15, MedPAC released its June 2022 Report to Congress. The report covers a range of Medicare payment issues including chapters on APMs, improving the accuracy of MA payments, and addressing the cost of Part B drugs. In this report, the commission provides specific suggestions to operationalize last year’s recommendation that CMS should reduce the number of APMs in Medicare. The commission outlines suggestions that include reducing the number of ACO tracks, eliminating the periodic rebasing of ACO benchmarks, and developing a national episode-based payment model to work concurrently with ACOs.

NAACOS is pleased to see that MedPAC continues to dedicate attention to improving the ACO model and APMs. When it comes to better harmonizing episode-based models with population-based models like ACOs, MedPAC left a lot of detail up to CMS, opting instead to give some broad, high-level principles that make sure ACOs are helped not harmed by a new program. While NAACOS has some concerns about how mandatory episodes would interact with ACOs, we appreciate that MedPAC’s report emphasized for CMS that allocating savings between models must be done in a way so incentives for the ACO to save and participate are considered. A NAACOS summary of the June 2022 MedPAC Report is available.

NAACOS ENDORSES LEGISLATION ON QUALITY MEASURES FUNDING
On June 23, Reps. Judy Chu (D-CA) and Buddy Carter (R-GA) introduced the Promoting Health Care Quality Act of 2022 (H.R. 8201). Each year, Congress provides funding to Medicare to support and strengthen healthcare quality measurements. Unfortunately, these funds were reduced in last year’s budget by $6 million. This bipartisan legislation restores previous funding levels to sustain existing quality programs and address national healthcare quality and patient safety priorities in 2023. With Congress currently considering fiscal 2023 funding legislation, NAACOS is proud to join the National Quality Form and others endorsing this important legislation.


CMS POSTS 2021 MIPS SCORE PREVIEWS
CMS recently posted 2021 score previews for the Merit-Based Incentive Payment System (MIPS). This preview period will be open until the final score and resulting payment adjustment amounts are provided, which CMS anticipates will take place in August. These 2021 scores determine 2023 payment adjustments. During the preview period, performance category level scores and bonus points will be available. ACOs can access this preview data by having APM entity representatives with the security official or staff user roles access the Quality Payment Program (QPP) portal using your ACO-MS username and password. If you feel there is an error with your score, or if you have any questions, CMS recommends contacting the QPP Help Desk at QPP@cms.hhs.gov.

CMS OUTLINES BUSINESS CASE FOR ADDRESSING HEALTH-RELATED SOCIAL NEEDS
This month, CMS published a new resource, “Making the Business Case for Addressing Health-Related Social Needs” (HRSNs) based on lessons learned from the Accountable Health Community (AHC) Model. The resource spotlights Reading Hospital’s Community Connections Program (CCP), which was created to implement the AHC Model, conducting screening, referral, and community service navigation for HRSNs of Medicare and Medicaid beneficiaries. The CCP focused on demonstrating a return on investment (ROI) to create buy-in among hospital leaders, identifying avoidable emergency department (ED) use as the most meaningful metric. In a 12-month period, the CCP was able to reduce avoidable ED visits by 15 percent, which correlated with an estimated $1 million in savings. In conjunction with the demonstrated cost savings, the CCP team also developed case studies and patient success stories to convey the importance of addressing HRSNs. These efforts resulted in hospital leadership agreeing to provide sustainable funding for the CCP’s HRSNs work. The AHC Model was operated by the CMMI for a five-year performance period beginning May 1, 2017, to test whether providing support for service delivery approaches that link beneficiaries with community services to address HRSNs can affect health care costs and reduce health care utilization. Early findings show the model holds promise for reducing ED use among Medicare beneficiaries.

HEALTHY FUTURES TASK FORCE RELEASES PLAN ON DOCTOR-PATIENT RELATIONSHIP
Last year, House Republicans established the Healthy Futures Task Force to outline a health policy agenda should the House flip in the upcoming election. On June 21, the Task Force’s Doctor-Patient Relationship Subcommittee released an outline of principles to improve the relationship between doctors and patients. The subcommittee outlined the needs to improve quality metrics, address electronic health record compatibility, provide certainty surrounding provider reimbursement, and reform prior authorization. NAACOS has been engaging with the task force and looks forward to working with Members of Congress to support policies that strengthen Medicare’s value-based care programs.

CMS BEGINS PAYING 2020 ADVANCED APM BONUS
This week CMS began distributing bonus payments to clinicians who were Qualifying Advanced APM Participants (QPs) based on their 2020 performance. Additional information is expected to be available on the QPP website in the coming days. If your ACO sees something that looks inaccurate, please to let us know by emailing us at advocacy@naacos.com and contacting the QPP Help and Support Center.

The agency will also begin publishing QP determinations for 2022 performance on the QPP Participation Status Tool in July after the first snapshot. As a reminder, performance year 2022 is 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. Contact your member of Congress today to ask them to support an extension of these critical incentive payments for value-based care providers.