NAACOS Newsletter for Members and Partners March 10, 2022

CMMI’S FOWLER TO KEYNOTE, UPDATE ON REACH MODEL AT SPRING CONFERENCE 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 on April 27–29 at the Hilton Baltimore Inner Harbor and hear from leading value-based care experts and CMS officials sharing timely and essential information for ACOs and other alternative payment models. Elizabeth Fowler, Ph.D., J.D., CMS Deputy Administrator and Director of the Center for Medicare and Medicaid Innovation (CMMI) will open Day Two with an update on the new ACO REACH Model and other initiatives to support value-based care. Our conference will close with our popular CMS Town Hall featuring CMS officials answering your questions. A detailed agenda is now available! Last Days to Register Early and Save Register before March 11 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 11 and receive a discount of $100 per person. **GROUP RATES** 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. Proof of vaccination required to attend in-person.

Welcome New Business Partners Accresa Accresa empowers the most respected healthcare systems in the nation to develop, implement, and administer subscription care plans through customizable plan designs, automated enrollment, payment efficiency and easy user experience. accresa.com/ Experian Health Experian Health’s Care Management solutions are designed for healthcare entities of all types to succeed in an era of value-based care through community-wide care coordination, leveraging real-time ADT integrations, rules-driven workflow, the use of SMS or email notifications in real-time and leveraging our Social Determinants of Health capabilities. experian.com/healthcare Kona Medical Consulting We are a white-label full-scope managed service organization (MSO) partner for Accountable Care Organizations (ACOs). As an MSO, we can provide all the core services that an ACO needs to operate and we can provide the same for their downstream member clinics. konamedicalconsulting.com

DEADLINE TODAY TO DECREASE REPAYMENT MECHANISM AMOUNT Following NAACOS advocacy to minimize burdens with required Medicare Shared Savings Program (MSSP) repayment mechanisms, CMS finalized a policy to cut in half the required amounts for ACO repayment mechanisms. Specifically, the new amounts are based on the lesser of either: 0.5 percent of total per capita Medicare Parts A and B fee-for-service expenditures for the ACO’s assigned population, or 1 percent of the total Medicare Parts A and B revenue of ACO’s participants. Based on these revised amounts, some ACOs are eligible to lower their repayment mechanism amounts, but they must act no later than today to do so. ACOs that are eligible for this one-time opportunity to decrease their repayment mechanism amount received notification earlier this month because their recalculated repayment mechanism amount for Performance Year (PY) 2022 is less than the ACO’s existing repayment mechanism amount. ACOs can log into the ACO Management System (ACO-MS) to access and review the formal notice and detailed instructions on next steps. If an ACO takes no action to submit uploaded revised repayment mechanism documentation, CMS will consider the ACO to have declined the one-time repayment mechanism amount decrease opportunity. NAACOS LAUNCHES ACO REACH COALITION; FIRST WEBINAR AVAILABLE ON-DEMAND NAACOS is proud to launch the ACO REACH Coalition, a new coalition dedicated to promoting shared learning and advocating on behalf of providers in Medicare’s newest value-based payment model. The coalition will provide in-depth resources and education to providers considering and later participating in the model when it begins next year. Specifically, the coalition will produce webinars and resources that analyze key details and aspects of the model, house key resources, hold in-person conference sessions and networking events, and provide a dedicated listserv to engage with peers about the model, among other benefits. Additionally, the ACO REACH Coalition will provide advocacy to improve the model to benefit the patients and providers involved in it. Current NAACOS members will enjoy all of these benefits and nothing additional is needed to access our webinars and resources. We encourage NAACOS members to share information about the new coalition with those who are not yet part of NAACOS and would benefit from the coalition. The first webinar held by the coalition is now available on-demand on our website. We hosted CMMI’s Pauline Lapin to answer questions about ACO REACH, following our overview. We also have a brief summary that explains the numerous improvements of ACO REACH over Global and Professional Direct Contracting (GPDC). Overall, NAACOS was pleased to see changes announced in ACO REACH, following advocacy to keep the model from being terminated. Among the many advocacy wins NAACOS saw were: Keeping CMMI’s premier ACO model with a new name to better reflect how it’s part of the evolution to accountable care Allowing a 2023 cohort, which many ACOs had been asking for Permanently canceling the Geographic Direct Contracting Model Reducing the discount in the global risk option, which makes full risk accessible to many more ACOs Placing more emphasis on equity, which NAACOS has devoted attention to how CMS could address Giving more transparency into model participants such as risk-sharing arrangement and capitation payment type. As a reminder, the application window for ACO REACH opened on March 7 and applications are due by 11:59 PM ET on April 22, 2022. More details can be found in the request for applications and any changes to the application timeline will updated on the ACO REACH Model page. NAACOS WEBINAR ON IMPACT OF RISK ADJUSTMENTS TO PERFORMANCE OUTCOMES NAACOS will hold a webinar on March 24 at 3:00 pm ET titled, The Outsized Impact of Risk Adjustment on ACO and DCE Performance and How It Fits into Your Financial Optimization Strategy. This event will feature Jeffrey Cumplido, MD, MPH, physician and risk adjustment expert at Lifespan, and Andrew Webster, ASA, MAAA, Chief Actuary, and David Portnoy, Chief Technology and Data Officer at Validate Health, an actuarial advisor to NAACOS. This webinar will show how risk adjustment affects ACO financial performance such as risk adjustment related reductions to ACO benchmarks that caused the forgoing an average of $1.4M in shared savings, with the top quarter of ACOs dropping $3.7M in 2020. This event will give a deep dive into the uses, implications, and strategies of risk adjustment optimization efforts for MSSP ACOs, DCEs and newly announced REACH ACOs. Experts will deliver the basics, such as the mechanics of hierarchical condition category (HCC) gap closure efforts, risk score calculations, how risk scores impact your benchmark and ultimately your shared savings. They will also provide observations on how COVID-related care avoidance affects risk scoring. Next they wil cover methods to build a business case for risk adjustment optimization, stratify the return on investment of HCC gap closure by patient cohorts, and identify when efforts hit diminishing returns. Finally, speakers and attendees will take a step back to demonstrate how your risk adjustment strategy needs to be integrated with other key decisions, such as beneficiary attribution management, provider participant selection and track selection. This informative event is free for members. CMS ISSUES 2021 QUALITY MEASURE CLARIFICATION As the 2021 quality reporting period comes to a close, CMS has issued a measure clarification for the 2021 Web Interface Measure HTN-2: Controlling High Blood Pressure. CMS clarified in a recent ACO Spotlight Newsletter that for the 2021 performance period, the measure denominator does include telehealth encounters. Regarding numerator compliance, CMS notes the following: For a blood pressure reading that’s taken by either a clinician or a remote monitoring device (i.e., a home device or a device brought by a visiting nurse or caregiver) and conveyed by the patient to their clinician, it’s considered acceptable for numerator compliance, as long as it’s the most recent blood pressure reading documented for the patient during the measurement period. CMS also notes the measure specifications don’t define remote monitoring device or methods of conveying the blood pressure from a remote monitoring device to the clinician. This allows for flexibility in the workflow of the interaction between clinicians and patients using remote monitoring devices during a telehealth encounter. Therefore, CMS is unable to provide guidance on a specific workflow other than it’s acceptable for numerator compliance. According to CMS it is up to the clinician’s discretion as to whether the remote monitoring device used to obtain the blood pressure is considered acceptable and reliable. The medical record documentation would need to support the quality action reported. As a reminder, the deadline to report 2021 quality data is March 31, 2022. NAACOS ANNOUNCES NEW EDUCATION OPPORTUNITY FOR MEMBERS! Learning Labs are a new educational activity for members designed to provide a deep dive into fundamental strategies in accountable care and to foster exchange among peers with frontline experience. These interactive “labs” will include expert presentations, experiences from member ACOs, brainstorming activities, and peer-led collaborations. NAACOS will be an active partner in these Learning Labs to understand what additional resources and tools members need to work through various administrative, operational, and transformational processes. These sessions will be structured to develop valuable resources to assist our members in the advancement of their value-based care efforts. Our first Learning Lab will launch in conjunction with the spring conference on Wednesday, April 27, 1:00 to 5:00 pm ET. Due to great interest from our membership, specialist engagement and incentives will be the topic for this inaugural in-person session. More activities and resources will follow throughout 2022 as lab participants identify educational needs. Registration for this lab is limited to NAACOS ACO members. Because there is no cost to register, we are limiting participation to one person per organization for the in-person event. Additional staff may participate in follow up lab activities held virtually. Register Today! If a representative from your ACO has expertise to present or would like to take a more active role in the lab, please reach out to Melody Danko-Holsomback, NAACOS Vice President of Education, mdholsomback@naacos.com. APPLICATIONS DUE FOR CMS’S KIDNEY CARE CHOICES PARTICIPATION CMS has released a request for applications for a second cohort of participants for the Kidney Care Choices Model to start in 2023. Responses are due on March 25, and CMS isn’t planning any further application cycles. The model includes Kidney Care First and Comprehensive Kidney Care Contracting, which are the kidney-specific versions of Primary Care First and GPDC. This NAACOS resource summarizes each model. CMS says there are no significant changes to Kidney Care Choices for next year. CMS REOPENS MIPS HARDSHIP APPLICATIONS CMS has reopened the Merit-Based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances (EUC) application due to the ongoing COVID-19 pandemic. Applications will be accepted through March 31, 2022, at 8:00 pm ET. For ACOs subject to MIPS, an official representative may submit a MIPS EUC application on behalf of all MIPS eligible clinicians in the ACO to receive a neutral MIPS payment adjustment for 2021 performance (paid out in 2023). To be eligible, more than 75 percent of MIPS eligible clinicians in the ACO must be eligible for reweighting in the Promoting Interoperability (PI) performance category. Note that applying for the MIPS EUC as an ACO will give all MIPS eligible clinicians in the ACO a neutral MIPS payment adjustment for the 2023 payment year. For more information, please see the Quality Payment Program COVID-19 Response page of the Quality Payment Program (QPP) website. CONGRESS NEARS BUDGET DEADLINE Congress is working this week to avoid a government shutdown when funding for the federal government expires on March 11. The prospects of a so-called omnibus package passing by the end of the week are complicated by funding requests from the White House of $22 billion in COVID-19 funding and $10 billion in funding for Ukraine, the latter of which appears to have greater bipartisan support. There continues to be disagreement among policymakers as to the response in Ukraine (e.g., whether to enforce a “no-fly” zone or supply additional planes), which is likely to continue over the coming week. Other riders, like an extension of COVID public health emergency (PHE) telehealth flexibilities, also hang in the balance while the Congress negotiates a larger package, including Fiscal Year (FY) 2022 appropriations and earmarks. Also this week, the Senate Finance Committee preps for a drug pricing hearing scheduled for March 14; a drug pricing package could serve as a “pay for” for other healthcare items, such as legislation related to value based payment, later in the legislative year. The Senate Health Education Labor and Pensions (HELP) Committee will also hold a hearing on that committee’s pandemic preparedness package on March 15. CMS MAKES DECISION ON 2021 COVID-19 ADJUSTMENTS FOR GPDC After analyzing COVID-19-related effects on 2021, CMMI has decided not to make any changes to financial methodologies in the GPDC Model. However, the agency says it will continue to monitor expenditure trends during the pandemic. CMS had told DCEs that if the observed trend differs from the prospective trend by more than one percentage point in a performance year, then the agency will consider using a retrospective trend adjustment. Citing reasons for not making changes, CMMI points to actual trend rates tracking very closely with the projected trend rate used in preliminary benchmarks at the start of the year. The agency also said it’s observing only slight increases in regional variability for both expenditure trends and risk score growth rates for PY 2021 relative to earlier years. This was communicated to DCEs through an email. NAACOS will continue to monitor the pandemic’s impact on spending in GPDC and all Medicare ACO programs and advocate for fair polices when needed. ASK LAWMAKERS TO EXTEND MACRA’S INCENTIVE PAYMENTS FOR ADVANCED APMS The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) included a 5 percent payment incentive to encourage Medicare providers to participate in Advanced APMs. These incentives have been instrumental in encouraging participation in Advanced APMs, but 2022 is the last performance year providers can qualify for bonuses. Thresholds to qualify for payment updates are also set for steep increases. NAACOS is calling on Congress to extend these incentive payments for six years and ensure Qualifying APM Participant (QP) thresholds remain attainable for providers going forward. With nearly 30 million traditional Medicare patients still in unmanaged and uncoordinated care, Congress must act this year to extend these incentive payments to encourage more providers to participate in Advanced APMs that have proven to save Medicare money and improve outcomes for patients. ACOs account for the majority of Advanced APM participants in Medicare, and lawmakers must hear from providers in their states about how important these payments have been in promoting value-based care. Visit NAACOS’ Take Action page to contact your representatives and senators today to urge them to extend the Advanced APM incentive payments! CMS RELEASES NEW RESOURCES FROM THE AHC MODEL Recently, CMS published three resources developed from lessons learned in the Accountable Health Communities (AHC) Model. These resources highlight sustainable strategies to address health related social needs (HRSNs) and include: A spotlight featuring one AHC participant’s multi-faceted clinical engagement approach used to foster a collective vision to address HRSNs, A resource focused on leveraging community partnerships, including key strategies for recruiting and engaging advisory board members, and A summary of key takeaways from a multistakeholder convening that included discussion of scaling sustainable screening, referral, and navigation activities beyond the AHC Model. The AHC Model facilitates collaborative partnerships between clinical delivery sites and community services providers to address HRSNs with the goal of aligning clinical care and social services to reduce avoidable health care utilization and costs. CMS INNOVATION CENTER RELEASES PLANS TO ADVANCE HEALTH EQUITY IN NEW ARTICLE Last week Dora Hughes, MD, PhD, authored an article in Health Affairs Forefront outlining CMMI’s four-point strategy for achieving the strategic objective to “advance health equity” as part of its 2030 vision, which includes the aim of embedding health equity in every aspect of CMMI models and increasing focus on underserved populations. Dr. Hughes, who serves as Chief Medical Officer for the Innovation Center, described four key ways in which equity will be embedded throughout models and initiatives: Develop new models and modify existing models to promote and incentivize equitable care Increase participation of safety net providers Increase collection and analysis of equity data Monitor and evaluate models for health equity impact Dr. Hughes then highlighted the ways in which the recently-released ACO REACH Model exemplifies the operationalization of CMMI’s new health equity strategy. ACO REACH includes several provisions aimed at advancing equity goals. Finally, Dr. Hughes emphasized the importance of interagency and multistakeholder collaboration, particularly with groups that have experience caring for underserved populations and those who have not historically engaged with CMMI in achieving the 2030 vision. PRESIDENT BIDEN PLANS TO INTEGRATE BEHAVIORAL HEALTH WITH PRIMARY CARE Last week, President Biden announced the administration’s strategy to address the national mental health crisis. This broad strategy is designed to transform the overall culture of mental health in the United States, both within and outside of health care settings. Included in the announcement are plans to integrate mental and behavioral health treatment into primary care settings, to direct the Department of Health and Human Services (HHS) to test payment models that support the delivery of whole-person, integrated care, and to expand access to telehealth and increase the behavioral health workforce in order to address access issues and provider shortages across the country. Additional details will be outlined in the President’s FY 2023 budget. NAACOS SUBMITS COMMENTS TO CMS ON PROPOSED 2023 CHANGES TO MA In a recent letter to CMS responding to proposed changes to Medicare Advantage (MA) in 2023, NAACOS requests the agency encourage MA plans to work with ACOs to both spur the country’s broader shift to value and better align payers’ efforts in value-based care work. CMS had sought feedback on developing a measure to assess the use of value-based contracts in MA. Also, NAACOS urged CMS to align risk adjustment policies across all of its programs, including traditional Medicare and MA to avoid arbitrage and profit-seeking based solely on risk scores. LAWMAKERS ASK BIDEN ADMINISTRATION TO SUPPORT ACOS AND DCES The House Innovation Caucus sent a bipartisan letter on March 8 asking the Biden administration to prioritize policy changes that will increase ACO participation. NAACOS supports the recommendations in the letter and believes these changes will advance the Biden administration’s goals of expanding accountable care. The final letter was signed by more than 40 lawmakers in the House. Reps. Ron Kind (D-WI) and Brad Wenstrup (R-OH) also led a letter on February 24 with colleagues asking the Biden administration to keep the Direct Contracting Model. NAACOS appreciates their leadership and was pleased to see the administration’s announcement regarding the transition into the ACO REACH Model for 2023. NAACOS would like to thank all our members that helped raise awareness about these important letters with their members of Congress. MEDPAC DISCUSSES APMS BEFORE JUNE REPORT TO CONGRESS During last week’s MedPAC meetings, the commission held a session discussing integrating episode-based and population-based payment models. This meeting was a continuation of the work the commission has been doing for the last year on APMs, and there will be a follow-up chapter on APMs in the June 2022 report that NAACOS will summarize for our members. 2020 QPP PERFORMANCE INFORMATION NOW ON CARE COMPARE CMS added new QPP performance information for doctors, clinicians, group practices, and ACOs to the Doctors and Clinicians section of Medicare Care Compare and in the Provider Data Catalog (PDC). CMS is required to report eligible clinicians’ MIPS final scores, MIPS eligible clinicians’ performances under each MIPS performance category, names of eligible clinicians in Advanced APMs and, to the extent feasible, the names and performance of such Advanced APMs.