NAACOS COMMENTS ON PROPOSED HCC RISK ADJUSTMENT CHANGES
Last month, the Centers for Medicare & Medicaid Services (CMS) proposed several changes to the hierarchical condition category (HCC) risk adjustment model, which is used by Medicare
Advantage (MA) plans and ACOs to account for clinical risk of their patient populations. NAACOS
submitted comments supporting CMS’s efforts to reduce over-payments in MA and create parity
between MA and Alternative Payment Models (APMs) in traditional Medicare. However, NAACOS cautioned that the agency should consider approaches to mitigate impact to provider payment, such as
phasing-in implementation over time. NAACOS is concerned about impact to ACOs. As such, we recommended that CMS:
Use the same HCC model version in the benchmark year and performance year to avoid bias that cannot be addressed by the renormalization factor,
Change MSSP’s risk score caps to +/-5 percent, and
Apply consistent caps to both the ACO risk score and the region’s risk score.
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CONGRESSIONAL UPDATES
PRESIDENT’S BUDGET PROPOSES REFORMS TO EXTEND MEDICARE SOLVENCY
The President’s Fiscal Year 2024 budget request to Congress includes a plan to extend the solvency of Medicare. A
fact sheet
from the White House is available. While the most recent Medicare Trustees Report projects that Medicare’s Hospital Insurance Trust Fund would be insolvent in 2028, the President’s budget
would extend solvency at least into the 2050s. The budget proposes:
Increasing Medicare’s tax rate on incomes above $400,000 and closing loopholes,
Crediting savings from prescription drug reforms to the Trust Fund,
Capping Part D cost sharing on certain generic drugs, and
Eliminating cost-sharing for three behavioral health visits per year and requiring parity between physical and mental health services.
Although the President’s budget is aspirational, it does outline the administration’s top priorities for the upcoming year. The budget request will also increase the ongoing debate in Congress
about extending Medicare’s solvency. Administration officials will begin testifying before congressional committees in the weeks ahead as lawmakers begin the annual appropriations process.
ADMINISTRATION UPDATES
PTAC DISCUSSES SPECIALTY ENGAGEMENT IN ACOS: COMMENTS DUE APRIL 7
The Physician Focused Payment Model Technical Advisory Committee (PTAC)
March meeting discussed specialist integration within total cost of
care models. Topics included improving specialty integration in ACOs and in advanced primary care models, options for defining and embedding specialty episodes within population-based models,
how to structure financial incentives and identify appropriate performance measures, and how to include safety net and rural providers in this work. PTAC is soliciting public comment on this
topic through April 7 at PTAC@hhs.gov. NAACOS will be submitting comments and will share a draft with members prior to the deadline.
CMS ANALYZES ACOS’ USE OF 3-DAY SNF WAIVER
A new report from CMS shows use of the 3-day skilled nursing facility (SNF) waiver for ACOs
resulted in better patient outcomes. The analysis focused on ACOs’ use of the waiver between 2014 and 2019 before all traditional Medicare beneficiaries were allowed to use the waiver under
the COVID-19 Public Health Emergency (PHE). Beneficiary stays under the waiver had lower or similar adverse outcome rates compared to beneficiaries not under the waiver. However, only between
3 and 5 percent of SNF stays were through the waiver.
FACT SHEET PROVIDES MORE DETAIL ON PHE’S EXPIRATION
CMS continues to release information regarding the end of the COVID-19 PHE. Most recently, the agency released a
fact sheet on various waivers
and flexibilities. The fact sheet covers:
COVID-19 vaccines, testing, and treatments;
Telehealth services;
Health care access: Continuing flexibilities for health care professionals; and
Inpatient Hospital Care at Home: Expanded hospital capacity by providing inpatient care in a patient’s home.
EARLY REGISTRATION DEADLINE NEXT WEEK FOR SPRING 2023 CONFERENCE
Register before March 17 for discounts on in-person and virtual registration for the upcoming conference on May 3–5 at the
Hilton Baltimore Inner Harbor. In addition to plenaries with CMS officials and other value-based care leaders, the conference will feature
16 breakout sessions with actionable knowledge for new ACOs joining the MSSP and REACH models, rural ACOs, independent primary care
ACOs, and experienced ACOs in all models.
Those registering before March 17 save $300 per person on in-person rates and $100 on virtual participation. We also offer deep discounts for ACO members on group registration for both the
in-person and virtual conference. To register a group, please contact Emily Perron. All rates will increase after March 17.
Exhibitor and sponsor opportunities are still available! The conference will feature exhibitors with products and services specifically for the accountable care community.
Partners reserve your space today!
ACO REACH LEARNING DISCUSSION TACKLES DATA ISSUES
NAACOS’ next ACO REACH Learning Discussion will take place March 17 from 12:00–1:00 pm ET. This month will focus on analytics and data sharing. Participation is limited to those participating
in ACO REACH, and advance registration is required. If you have questions or
additional topics you want discussed, please share them in advance by emailing
acoreach@naacos.com.
DISCOVERY CALL FOR ARCADIA USERS
As requested by our ACO members, NAACOS will hold a discovery call for ACO members using the Arcadia product to learn from each other. This call will take place on March 30 from 2:00 to 3:00
pm ET. After some brief presentations by member ACOs, there will be an open discussion on how ACOs are using the platform in their ACOs.
Sign-up to attend this event.
ACO MEMBERS: GET UNDER WAY WITH COMPLIANCE
NAACOS has released an updated MSSP Compliance Manual and a new ACO REACH Compliance Manual.
Why should you purchase the manual? ACOs are required to meet a large number of state and federal regulatory requirements, including health care fraud and abuse laws, privacy
requirements, and the specific requirements of CMS. This manual is a necessary tool designed to provide template policies to help your leadership determine the best “next steps” for your
organization and implement procedures to ensure compliance with program requirements. Your ACO may have purchased a previous version of this Compliance Manual. If so, upgrading to this newest
version will provide additional compliance and operational insight, as well as the addition of required policies around care coordination, beneficiary engagement, internal reporting on data
and analytics, marketing material requirements, and more! Purchase a Compliance Manual.
Upcoming Webinars Building an Effective MSSP Compliance Program on March 14, 2:00–3:00 pm ET: Join ACO Compliance
expert, Kimberly Busenbark, as she details the keys to implementing and operating an effective MSSP Compliance Program. Get actionable advice on best practices for required documentation,
successfully navigating audits, avoiding high risk areas, and meeting regulatory changes in Performance Year 2023. Speaker:
Kimberly Busenbark
Building an Effective ACO REACH Compliance Program on March 16, 2:00–3:00 pm ET: Join ACO
Compliance expert, Kimberly Busenbark, as she details the keys to implementing and operating an effective ACO REACH Compliance Program. Get actionable advice on best practices for required
documentation, successfully navigating audits, avoiding high risk areas, and working with operations to set up compliant processes under the ACO REACH Model. We will discuss compliance program
documentation as well as updates from Global and Professional Direct Contracting to ACO REACH and their impact on operational compliance. Speaker:
Kimberly Busenbark
MEMBER RESOURCES
DISCOVERY CALL ARCHIVES AVAILABLE
Have you missed any of the recent NAACOS Discovery Calls? The Discovery Call page includes recordings of calls on paramedic
program ROI, specialist engagement, physician compensation, HCC gaps, end of life care and documentation, EPIC claims Ingestion, and soon to be added — MSSP beneficiary notification. This
library will continue to grow as we hold discussions on popular and timely topics raised on the NAACOS ListServ.
HAVE A QUESTION? ASK YOUR PEERS
Your membership includes access to our exclusive ListServs for ACO members. These tools allow you to send messages and ask
questions through a single email distributed to all ACO members subscribing to the list! Here are the most recent discussion topics:
NEW ACO MEMBER BENEFIT: UNDERSTAND YOUR SPENDING ON BPCI EPISODES
NAACOS in partnership with the Institute for Accountable Care is offering complimentary episode spending reports to all ACO members. The reports are based on 2021 spending for each ACO’s
attributed beneficiaries grouped into 34 Bundled Payment for Care Improvement (BPCI) Advanced 90-day episodes. The reports provide aggregate results for each bundle by type of service along
with a state-level comparison group. The episode reports will show your ACOs:
The volume and average spending for each 90-Day BPCI clinical episode for your ACO’s attributed beneficiaries in 2021.
The relative ‘efficiency’ of the episodic care your beneficiaries received as indicated by the observed-to-expected ratio. This measure uses risk-standardized episode spending.
Per-episode spending for major categories of service such as skilled nursing and hospital readmissions for each episode.
Comparisons to your state’s average episode spending.
