DON’T MISS THE OPPORTUNITY TO LEARN FROM AND NETWORK WITH ACOS!! Get the best and latest information on ACO policy and practices at the NAACOS Spring 2021 Conference! Along with a keynote by ACO thought leader, Dr. Mark McClellan, a fireside chat with SCAN CEO, Dr. Sachin Jain, and a closing town hall with CMS officials, the conference will feature deep dives into critical issues for ACOs and other value-based payment models.
The spring virtual conference will take place over two weeks in April with information-filled sessions as well as opportunities to interact with peers and vendors. Sessions will be held from 11:00 am–4:00 pm ET. As in the past, the recordings will be available to access for six months post-conference. A detailed agenda with times, speakers, and descriptions has been posted.
New for the Spring 2021 Conference is our group rates for ACO members and business partners. Group rates are not available to non-members. To take advantage of these rates, please contact Emily Perron.
Opportunities for Business Partners The conference will feature a virtual exhibit hall where attendees will be able to meet with exhibitors online! Features will include virtual meet-ups, appointment setting, product photos, and MUCH more! Opportunities for business partners include:
Become a $10K sponsor that includes a 12-minute recorded commercial played between sessions during the virtual event
Exhibit at our virtual exhibitor hall—complementary to all business partners, but sign up is required
CONGRESS PASSES $1.9B AMERICAN RESCUE PLAN On March 10th, the U.S. House of Representatives passed the American Rescue Plan, or Biden COVID-19 stimulus plan by a vote of 220 to 211. The passage followed a series of amendments in the U.S. Senate, including removal of a provision that would have required a national $15 minimum wage. The American Rescue Plan includes funding for COVID-19 testing and rural hospitals, expands Affordable Care Act (ACA) insurance subsidies and cost sharing support for the unemployed, and extends support for skilled nursing facilities (SNFs) and ambulance providers. Following the passage of this stimulus, Congress is expected to turn to a second reconciliation measure aimed at infrastructure and additional aid to combat the COVID-19 pandemic.
INNOVATION CENTER RELEASES MORE DIRECT CONTRACTING DETAILS The Center for Medicare and Medicaid Innovation (Innovation Center) has released the Participation Agreement and preliminary benchmarks for direct contracting entities (DCEs) participating in Performance Year (PY) 1, which starts on April 1. The 290-page Participation Agreement should provide many more details on the program to DCEs, and NAACOS has created a new resource showing important takeaways. The deadline to electronically sign the Participation Agreement is 8:00 pm ET on March 29.
The Innovation Center also released a number of other guidance documents including financial guarantees and contracting with downstream providers. This and other important information are posted on NAACOS’ Direct Contracting page . The Innovation Center will also host a series of webinars and office hours in coming weeks for PY1 participants.
NAACOS SURVEY ON MSSP QUALITY CLOSES SOON Medicare Shared Savings Program (MSSP) ACOs continue to ask questions about and express concerns over the MSSP quality reporting overhaul. While a number of important changes went into effect in 2021, more notable changes are scheduled for 2022. For example, in 2022 CMS will end use of the Web Interface reporting option and will require use of electronic Clinical Quality Measures (eCQMs). To help CMS understand ACO readiness for these changes, NAACOS is conducting a survey. This has been sent to all MSSP ACOs, most recently on Tuesday, with an email that included the subject line, “Are You Ready for the Impending Medicare ACO Quality Overhaul?” If you need assistance locating your ACO’s survey, please contact Sam Sobul. The survey will close March 15th, so don’t wait!
In addition to advocacy on the MSSP quality overhaul, NAACOS has numerous resources to help ACOs understand these changes. As a member of NAACOS you have free access—take advantage of these tools today!
GEOGRAPHIC DIRECT CONTRACTING, OTHER MODELS UNDER REVIEW AND DELAYED In a win for NAACOS advocacy, the CMS Innovation Center announced it was reviewing the Geographic Direct Contracting Model and that its application period, scheduled to start this month, wouldn’t take place. NAACOS has been arguing that the “Geo” Model would undermine the work of ACOs and their existing relationships with patients, and we have been calling on the Innovation Center to stop the model’s implementation. We are glad to see this take place and continue to urge adjustments in the Global and Professional Options of Direct Contracting. It’s unclear to us when or if the Geo Model’s implementation will continue.
Last week, the Innovation Center also announced it was reviewing the Seriously Ill Population component of Primary Care First, which aims to identify high-needs beneficiaries who are experiencing fragmented, uncoordinated care and to deliver intensive, episodic interventions to stabilize their conditions. Practices in the model receive higher CMS payments. This NAACOS resource summarizes Primary Care First, and we are uncertain of why the model is being reviewed or when the review will be completed. Kidney Care First and Comprehensive Kidney Care Contracting, which are two models specific for patients with end-stage renal disease, will be delayed until 2022. They were to start next month. NAACOS compiled this summary of those two models to help ACOs better understand how they work.
CMS RELEASES INFORMATION ON 2022 MSSP APPLICATION PERIOD ACOs interested in a 2022 start date in MSSP can submit a Notice of Intent to Apply (NOIA) from June 1 through June 7 at 12:00 pm ET. Although NOIAs are nonbinding, ACOs must submit one to be eligible to apply, renew, or early renew for MSSP participation. More details on the application process is on CMS’s site along with CMS’s application toolkit.
This year, CMS has streamlined the application process into two phases. In phase one, ACOs will first submit their Participant List, Skilled Nursing Facility (SNF) Affiliate List, and draft repayment mechanism documentation (if applicable). Phase one closes on August 3 at 12:00 pm ET, and this will be the final opportunity to add ACO participants. This is earlier than usual. During phase two, ACOs will submit other elements, including the governing body, organizational chart, attestations, and final repayment mechanisms (if applicable).
TELEHEALTH MODERNIZATION ACT REINTRODUCED, BACKED BY NAACOS NAACOS is proud to support the Telehealth Modernization Act, which was recently reintroduced in the House and Senate. The bill would make permanent certain telehealth flexibilities under Medicare allowed during the COVID-19 public health emergency. NAACOS believes that because ACOs take accountability for patients and are increasingly at financial risk for their spending and quality, all ACOs, regardless of their choice of attribution or level of risk, should be granted more freedom to use telehealth than providers not operating in these models.
NAACOS TO HOST NEXT DIRECT CONTRACTING LEARNING DISCUSSION ON MARCH 26 Please join NAACOS and your peers for our next Direct Contracting Learning Discussion. Melanie Matthews of MultiCare Connected Care and Elissa Langley of Triad HealthCare Network will lead the event. This collaborative discussion will provide a forum for shared learning, and we ask that you send questions or requested conversation topics in advance to directcontracting@naacos.com by March 24th so that we can make the most of this opportunity. NAACOS is hosting this forum as we anticipate members will be weighing their participation options for 2022. This event was previously scheduled for the 23rd, but we had to move it to because it conflicted with CMS Office Hours on Direct Contracting that hadn’t yet been announced. Register now!
NEW VERSION OF ACO DIRECTORY AVAILABLE NAACOS is pleased to release an updated version of its Directory of MSSP ACOs. A popular member resource, this directory succinctly organizes publicly available information from multiple years and sources into one concise and easy-to-navigate resource. The information includes attributes such as each ACO’s beneficiary size, shared savings, and quality performance scores. The resource includes all MSSP ACOs that were in operation in 2016, 2017, 2018, 2019, and/or 2020. Current NAACOS members and partners may download the ACO Directory.
NEW RESOURCE HIGHLIGHTS ACO SAVINGS IN 2019 NAACOS is out with a new resource that highlights not only MSSP and Next Generation ACO savings in 2019 but also Medicare ACOs’ historical contributions. Since 2012, ACOs have saved Medicare $8.5 billion and $2.5 billion after accounting for shared savings payments, shared loss payments, and discounts to CMS. Data show these ACOs continued to provide high-quality care and yield satisfied patients. This document helps demonstrate that there is no doubt ACOs are succeeding. NAACOS hopes to use this document to convince policymakers to look for opportunities to grow ACO participation so that benefits of the program can spread to more patients, while helping solve Medicare’s looming insolvency issues.
MSSP QUALITY REPORTING DEADLINE APPROACHES The MSSP quality reporting submission deadline is Wednesday, March 31, 2021. CMS will automatically accept the data entered in the Quality Payment Program (QPP) site as of Tuesday, March 31, 2020, at 8:00 pm ET. This information will be considered an ACO’s final submission. As a reminder, ACOs must have an appropriate user role associated with their organization with a Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) User ID and password to complete the submission process.
Additionally, for ACOs subject to the Merit-based Incentive Payment System (MIPS), the deadline for clinician practices and individual eligible clinicians (ECs) to submit their Promoting Interoperability (PI) data is also Wednesday, March 31, 2021. Practices and clinicians will report and attest to PI data also via the QPP site. Hospitals and Medicaid Eligible Professionals (EPs) also report PI data under separate hospital PI rules and requirements; the acute hospital, critical access hospital and Medicaid PI reporting deadline to submit is Thursday, April 1, 2021. More information on the hospital and Medicaid PI requirements are available.
Welcome New ACO Member
ASPA Connected Community, LLC. Nashville, TN
NAACOS SUPPORTS BILL TO IMPROVE SOCIAL DETERMINANTS OF HEALTH Several senators recently introduced a bill that would provide funding for states to create or enhance public-private partnerships to coordinate health and social services. NAACOS supports the bill, which is called the Leveraging Integrated Networks in Communities to Address Social Needs Act, or LINC Act. NAACOS believes addressing patients’ social determinants of health, such as their food, housing, and transportation, is important to improving their health. More information can be found in the LINC Act’s text, section-by-section summary, one-pager and frequently asked questions.
DEADLINE FOR MIPS E/C APPLICATION APPROACHING CMS is reopening the MIPS extreme and uncontrollable circumstances (E/C) application through March 31, 2021, at 8:00 pm ET. This extension applies to Alternative Payment Model (APM) entities that have MIPS eligible clinicians who are not qualifying APM participants and if certain other criteria are met. Specifically, if an APM entity opts to apply for this relief, it is required to request reweighting for all performance categories, and more than 75 percent of the MIPS eligible clinicians in the APM entity must be eligible for reweighting in the PI performance category. If an APM entity previously submitted data, that submission will be overridden if the application for performance category weighting is approved.
If the application is approved, the APM entity will receive a final score equal to the performance threshold and the MIPS eligible clinicians will get a neutral payment adjustment. Any approved application does not affect whether the entity needs to report the model-specific reporting requirements (such as the quality measures through the Web Interface to meet MSSP requirements). APM entities in MIPS must either report for the 2020 performance period or have an approved E/C application; otherwise, their MIPS eligible clinicians will receive the negative payment adjustment for the 2022 payment year. Additional information is available including application resources and the COVID-19 QPP page.
BECERRA NOMINATION PROCEEDS On March 3rd, the Senate Finance Committee favorably reported out the nomination of California Attorney General (AG) Xavier Becerra to be Secretary of the U.S. Department of Health & Human Services along a split party line vote of 14 ayes and 14 nays. The Senate Finance Committee’s vote followed hearings in that committee and the Senate Health Education Labor & Pensions (HELP) committee. During those hearings, several senators expressed strong support for value-based care, including a lengthy statement from Sen. Sheldon Whitehouse (D-RI) regarding the importance of ACOs specifically. The nomination now moves to the Senate floor for consideration, where it will be considered after four hours of debate and subject to a majority vote, per Senate rules. While AG Becerra’s nomination is still on track for confirmation, there has been significant activity by Republicans to block the nomination.
CMS EXTENDS DEADLINE FOR CHART MODEL COMMUNITY TRANSFORMATION TRACK CMS has extended the deadline to apply for the Community Transformation Track of the rural-focused Community Health Access and Rural Transformation (CHART) Model to May 11. Under this CMS Innovation Center model, communities receive upfront funding, capitated payments, benefit enhancements, and beneficiary engagements to coordinate care within communities. Background information is available on CMS’s website and in FAQs. CMS has said it plans to release the Request for Applications on the ACO Transformation Track of the CHART Model this spring. Participation in that track will be concurrent with MSSP.
MEDPAC SUPPORTS TESTING FEWER INNOVATION CENTER MODELS The Medicare Payment Advisory Commission (MedPAC), which makes policy recommendations about Medicare payment policy to Congress and CMS, supported a draft recommendation that the Innovation Center operate a smaller, more coordinated portfolio of APMs. Operating too many models—54 in the Innovation Center’s 10-year history—complicates work for providers, CMS, and evaluations because too often models overlap and conflict with one another. While MedPAC didn’t elaborate on which models should be kept or how they should be coordinated, NAACOS has written in the past that CMS should prioritize total-cost-of-care models because they’ve shown to work better than others. NAACOS continues to advocate for a more comprehensive model overlap policy from the Innovation Center. MedPAC will formally vote on the recommendation next month. Slides and a transcript from the meeting are available online.
