NAACOS Newsletter for Members and Partners March 24, 2022

Table of Contents
NAACOS Next ACO REACH Webinar on April 4
Specialist Engagement Challenges Addressed in Upcoming Learning Lab
Tell Lawmakers You Support ACO REACH
Congress Paves Way for 2022 Health Priorities
NAACOS Publishes ACO REACH vs MSSP Comparison Chart
Put Your Data to Work at NAACOS Summer Boot Camp
NAACOS Urges MSSP Changes
MSSP Application Deadlines Announced
Quality Reporting Deadline Approaches
Social Needs Included in PREVENT Pandemics Act Legislative Package
NAACOS Submits Feedback to CMS on Beneficiary Engagement Strategies
MedPAC Releases March Report
PTAC Publishes Environmental Scan of Total Cost of Care Models

NAACOS’ NEXT ACO REACH WEBINAR ON APRIL 4
Applications for the new ACO REACH Model are due on April 22, which gives precious little time for ACOs to understand the recently announced model. As such, NAACOS is holding its next webinar on ACO REACH at 3:00 pm ET on April 4. On this webinar, you’ll hear from an MSSP ACO about how they’re evaluating ACO REACH and what they view as the opportunities and challenges. Also, a current DCE will react to the recently announced changes to the Global and Professional Direct Contracting (GPDC) Model and what it means to them. Lastly, we’ll walk through the application, showing tips and tricks for applicants along the way. This follows up on NAACOS March 10 webinar that provides an overview of ACO REACH. We hope these webinars provide a deep dive into the model and help ACOs better understand what’s the best path for them. Registration is free for current NAACOS members and business partners as well as members of NAACOS’ ACO REACH Coalition.

Welcome New Business Partners
Geniq
Geniq offers proven work low and analytics solutions for provider groups, ACOs, and other health systems to succeed in delegated risk markets.
Geniq.com
Koda Health
Koda’s flagship Advance Care Planning (ACP) software platform provides everyday clinicians the ability to engage their patients in valuable conversations about their care preferences.
kodahealthcare.com
HealthJay
HealthJay is a California-based tech company offering a transformative Telehealth Operating System that is intended for use by health and human service providers to break down access barriers for vulnerable populations to access care.
healthjay.com
Visby Medical
Visby Medical’s proprietary technology development program culminated in the world’s first instrument-free, single-use PCR platform that fits in the palm of your hand and rapidly tests for serious infections.
visby.com
SPECIALIST ENGAGEMENT CHALLENGES ADDRESSED IN UPCOMING LEARNING LAB
NAACOS will be kicking off our first Learning Lab activity on April 27 in conjunction with the spring conference in Baltimore. This lab will focus on specialist engagement and incentives, and it is designed to provide a deep dive into fundamental strategies in accountable care and to foster exchange among peers with frontline experience. Additional resources available to members on specialist integration include previous conference presentations found in our conference archives. Additionally, a copy of the ACO Guide to Specialist Manual is also available for your review.

If you would like to attend the Learning Lab and are a NAACOS ACO member, you can register at no cost. We are limiting participation to one person per organization for this 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, [email protected].

TELL LAWMAKERS YOU SUPPORT ACO REACH
Following advocacy efforts by NAACOS, the Center for Medicare and Medicaid Innovation (Innovation Center) announced on February 24 that GPDC would transition into a new ACO REACH Model in 2023 that focuses more on health equity and provider governance. While NAACOS supports ACO REACH, there are still several lawmakers asking the Biden administration to cancel the model. As questions about the benefits of value-based care are raised on Capitol Hill, lawmakers need to hear from ACOs in their states and districts. NAACOS is asking our members to contact their representatives today to show support for value-based care and the new ACO REACH Model.

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CONGRESS PAVES WAY FOR 2022 HEALTH PRIORITIES
Following passage of the omnibus funding bill earlier this month, which included several high priority healthcare items (e.g., the temporary extension of telehealth waivers), congressional lawmakers are now focused on non-healthcare matters, such as the conflict in Ukraine, passage of the America COMPETES Act, and the confirmation hearing for U.S. Supreme Court nominee Ketanji Brown Jackson.

On the healthcare front, legislators in the majority party are clearly outlining their priorities for the remainder of the legislative year: drug pricing, mental health, and user fee reauthorization are top issues. Additionally, depending on multiple factors including the emergence of new COVID variants, more pandemic relief and preparedness funding may also advance. The latter issue is particularly timely: as of March 22, Health and Human Services’ (HHS) Uninsured Program is no longer accepting new claims for COVID testing and treatments, and the administration has been stressing the need for additional funding. The President’s 2023 Budget request is also due this week, which will outline the administration’s upcoming priority healthcare items.

NAACOS PUBLISHES MSSP VS. ACO REACH COMPARISON CHART
Recently, NAACOS has published several resources on the newly announced Innovation Center model, ACO REACH, as part of the NAACOS REACH Coalition. With the application window for ACOs to participate in the REACH Model for Performance Year (PY) 2023 now open through April 22, ACOs may be grappling with the decision to participate in the Medicare Shared Savings Program (MSSP) or the ACO REACH Model. To highlight the key differences between the advanced tracks of MSSP (Level E and Enhanced) and the Professional and Global tracks of REACH, NAACOS has published a comparison chart for members. The chart describes general program information, financial structures, beneficiary alignment methodologies, quality requirements, and compliance and waiver information for each track. For more information or if you have questions, you can contact [email protected].

PUT YOUR DATA TO WORK AT NAACOS SUMMER BOOT CAMP
Having the right data at the right time is the key to understanding the underlying factors that determine your ACO’s population outcomes and your success in value-based care. At the NAACOS 2022 Summer Boot Camp on June 16–17 in Nashville you will learn from ACO leaders and technical experts how to harness your data to drive positive performance outcomes.

Boot camp faculty will:
  • Demonstrate how to understand risk calculations analysis, comparison, benchmarking, and trending,
  • Explore best practices for creating actionable dashboards and reports,
  • Provide information on considerations when building episodes within ACO data,
  • Explain claims data variation and how to create accurate network reports for acute and post-acute settings, and
  • Show how to use data requirements to drive practice transformation.
This boot camp is designed for the ACO leadership team, including executive directors, population health staff, as well as data, analytics, and IT team members. We will have workshops that speak the language of those responsible for data management and reporting in ACOs. Registration is now open! Space is limited to 100 people!
Welcome New
Associate ACO Member

UpStream
Greensboro, NC
NAACOS URGES MSSP ENHANCEMENTS
In a letter to CMS, NAACOS recently urged the agency to implement a number of program enhancements to drive increased participation in MSSP. In particular, NAACOS urged CMS to consider these policy recommendations for inclusion in the 2023 Medicare Physician Fee Schedule Rule to reverse a concerning decline in participation. In the letter, NAACOS urges CMS to restore shared savings rates to pre-Pathways levels, address benchmarking flaws, and address flawed quality rules for ACOs, among other things. NAACOS will continue to press CMS to make these needed changes to drive additional participation in value-based care and to fulfill CMS’s goal of having all Medicare patients in an accountable care relationship by 2030.

MSSP APPLICATION DEADLINES ANNOUNCED
Earlier this month, CMS issued updated information on the MSSP application process and timeline for the January 1, 2023 start date. The Notice of Intent to Apply (NOIA) submission window opens on June 1 and will close on June 7 at 12:00 pm ET. Be sure to gain access to the CMS ACO Management System (ACO-MS) to submit your NOIA. ACOs must submit a NOIA in order to be eligible to submit a full application, but the NOIA is nonbinding. Phase 1 of the application process will open on June 8 and the window for this phase of the application closes June 29 at 12:00 pm ET. A CMS application toolkit is available with helpful guidance and resources. Additional information about the application timeline is available and updated sample applications will be posted soon. As a reminder, application dates are subject to change.

QUALITY REPORTING DEADLINE APPROACHES
As a reminder, the last day to submit PY 2021 quality data is March 31, 2022, at 8:00 pm ET. 2021 is the first year the new quality scoring rules apply to all MSSP ACOs. Under the new Alternative Payment Model [APM] Performance Pathway (APP) structure, for PY 2021 MSSP ACOs can choose to report either 10 Web Interface measures or three electronic clinical quality measures (eCQMs) or Merit-based Incentive Payment System (MIPS) CQMs (supported by a registry). Reporting will take place via the Quality Payment Program (QPP) website. CMS advises ACOs to ensure they have the necessary Health Care Quality Information System Access Roles and Profile (HARP) accounts. ACOs can manage their HARP user roles in the ACO-MS. This includes ensuring the ACO has a QPP Security Official listed in the ACO-MS. CMS has provided tip sheets and user guides to assist with this process, available in the ACO-MS. Access our new resource to learn more about your ACO’s quality reporting options for 2021 through 2025, as well as important changes to quality scoring that can have a significant impact on your ACO and your shared savings.


SOCIAL NEEDS INCLUDED IN THE PREVENT PANDEMICS ACT LEGISLATIVE PACKAGE
Following a letter signed by NAACOS and over 50 other organizations in February, the Senate Health, Education, Labor, and Pensions (HELP) Committee has included key social determinants provisions in the bipartisan Prepare for and Respond to Existing Viruses, Emerging New Threats, and Pandemics Act (PREVENT Pandemics Act). This includes the bipartisan, bicameral Leveraging Integrated Networks in Communities (LINC) to Address Social Needs Act (S. 509/H.R. 6072), which will enable states to establish or enhance community integration network infrastructure to facilitate cross-sector referrals and manage the interconnected health and social needs of individuals. The bill passed the Senate HELP Committee on March 15.

NAACOS SUBMITS FEEDBACK TO CMS ON BENEFICIARY ENGAGEMENT STRATEGIES
This week, NAACOS submitted comments in response to the Innovation Center’s beneficiary engagement strategy, as discussed in a recent listening session. As part of the operationalization of the strategic direction outlined in the 2021 strategy refresh paper, the Innovation Center intends to incorporate beneficiary perspectives into model testing, implementation, and evaluation. Incorporating diverse beneficiary perspectives in a meaningful way will be necessary to achieve the Innovation Center’s health equity goals. Appropriate and accessible beneficiary education will also be necessary to drive accountable care and achieve the goal of having all traditional Medicare beneficiaries in an accountable care relationship by 2030. NAACOS shared feedback on strategies to improve beneficiaries’ understanding of and engagement with value-based care.

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MEDPAC RELEASES MARCH REPORT
On March 15, the Medicare Payment Advisory Commission (MedPAC) published its March report on Medicare payment policy. The report includes recommendations on Medicare fee-for-service (FFS) payment systems, the Medicare Advantage (MA) program, and the Medicare prescription drug program. Below are highlights from the commission’s recommendations.
  • Payment: The commission recommends positive payment updates in 2023 for three FFS payment systems (hospital, long-term care hospital, and outpatient dialysis); no update for three systems (physician, ambulatory surgical center, and hospice); and negative updates for three systems (skilled nursing facility, home health, and inpatient rehabilitation facility).
  • Telehealth: The commission recommends that the Secretary of HHS require physicians and other health professionals, home health agencies, and hospices to provide more information on the telehealth services they provide. This information would be used to help policymakers assess the impact of these services on access, quality, and costs.
  • Post-Acute Care:
    The commission included a chapter outlining a prototype value-based payment program under a unified prospective payment system for post-acute care services. The commission concluded that implementation of a new payment system would be a multiyear process that would eventually need to align regulatory and quality incentives tied to MA and ACO payments.
  • Medicare Advantage: The report included data showing that MA grew by 10 percent for the third consecutive year. MA is now projected to cover a majority of eligible Medicare beneficiaries by 2023. The commission further illustrated that Medicare spends 4 percent more on MA than it would spend on FFS Medicare, and private plans in the aggregate have never produced savings for Medicare. While MedPAC remains committed to including private plans in the Medicare program, the commission has concerns that as enrollment continues to grow, the current MA payment system will further worsen Medicare’s fiscal sustainability.
On March 4, NAACOS sent a letter to the Biden administration asking 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. NAACOS was encouraged that HHS Secretary Xavier Becerra said in an interview on March 18 that the Biden administration is examining risk adjustment practices in MA plans that lead to overpayments by Medicare.


PTAC PUBLISHES ENVIRONMENTAL SCAN OF TOTAL COST OF CARE MODELS
Earlier this month, the Physician-Focused Payment Model Technical Advisory Committee (PTAC) released an environmental scan that provides background information and current perspectives on the role that population-based total cost of care (TCOC) models can play in health care delivery transformation and the overall shift to value-based care. PTAC is hosting a series of theme-based discussions dedicated to the topic of population-based TCOC models in 2022, the first of which took place earlier this month. PTAC’s June public meeting will focus on best practices in care delivery for population-based TCOC models and the September public meeting will focus on payment considerations and financial incentives related to these models. As part of this series, PTAC has issued a request for input (RFI) on issues related to population-based TCOC model design and implementation, which NAACOS will provide comments on. More information on PTAC’s work and upcoming meetings can be found on the PTAC site.