NAACOS HELPS LAUNCH ALLIANCE FOR VALUE-BASED PATIENT CARE
The Alliance for Value-Based Patient Care, a multi-organization public relations campaign aimed at extending the Advanced Alternative Payment Model
(APM) incentive payments, launched on Tuesday. NAACOS is spearheading the campaign, which will target members of Congress and their staff through earned and paid media. Please
read the press release and
visit the website to use its resources in your own advocacy.
NAACOS SUBMITS COMMENTS TO CONGRESS ON MACRA
NAACOS responded to a bipartisan request for information from a group
of House lawmakers asking for input on how to improve the Medicare payment system and expand value-based care.
NAACOS recommended that Congress:
Immediately extend the 5 percent advanced APM incentive payments and keep qualifying thresholds at attainable levels.
Revise the Medicare Access and CHI Reauthorization Act (MACRA) incentive structure in the future to remove ACOs from the Merit-Based Incentive Payment System (MIPS) and create a three-track payment
system that provides stronger financial incentives and flexibility for clinicians as they move to value;
Amend the Medicare statute to allow CMS to create a separate full-risk option within the Medicare Shared Savings Program (MSSP);
Direct CMS to create an option for MSSP ACOs to elect partial or full capitated payments for primary care and establish a common set of waivers for APMs; and
Establish more transparency and stakeholder engagement regarding the CMMI model review process.
NAACOS SUBMITS COMMENTS TO CMS ON EQUITY AND PROVIDER BURDEN
NAACOS is responding to a
request for information issued by CMS
on reducing provider burden and advancing health equity. NAACOS’ draft comments reiterate our
recommendations to leverage ACOs as a mechanism for reducing burden and providing additional support to providers, change the burdensome quality reporting approach, and provide additional flexibility in the
models to expand telehealth access and address patient social needs. Comments are due this Friday, November 4.
Welcome New ACO Members
Tuality Health Plan Services ACO Portland, OR
INTEGRIS Health Partners Oklahoma City, OK
Cape Code Healthcare ACO Hyannis, MA
CONGRESSIONAL UPDATES
LAWMAKERS FINALIZE LETTER TO HOUSE SUPPORTING ADVANCED APMS
A bipartisan group of House lawmakers sent a letter to House leaders requesting an extension
of the 5 percent advanced Alternative Payment Model (APM) incentive payments. Reps. Welch (D-VT), DelBene (D-WA), Blumenauer (D-OR), LaHood (R-IL), Wenstrup (R-OH), and Burgess (R-TX) led the letter that was
signed by more than 40 lawmakers. This builds on the stakeholder letter that NAACOS and 800
organizations sent to leaders in September. Thank you to all the NAACOS members that signed the stakeholder letter and helped build support for the congressional letter.
ADMINISTRATIVE UPDATES
CY23 MEDICARE PHYSICIAN FEE SCHEDULE FINAL RULE PUBLISHED
CMS released the
final 2023 Medicare Physician Fee Schedule (MPFS) Rule
on Tuesday. It contains numerous positive changes for the MSSP that NAACOS has long been advocating for, including a more appropriate onramp to risk, more realistic and favorable benchmarking policies,
favorable changes to quality scoring, and reduced regulatory burden.
Some of the key issues affecting ACOs include CMS policies to:
Decrease the Medicare conversion factor from $34.61 to $33.06 for 2023.
Change the current “Pathways to Success” glidepath to allow more time before advancing to risk, including allowing certain ACOs inexperienced with risk to participate in the program for up to seven
years before advancing to risk, and revising the number of agreement periods an ACO can participate in Basic Track Level E, making the Enhanced Track optional.
Revert to the sliding scale quality scoring approach to determine shared savings and extend incentives for reporting electronic clinical quality measures (eCQMs) through 2024.
Provide advance shared savings payments, referred to as advance investment payments, to low-revenue ACOs inexperienced with risk that serve underserved populations, including an upfront fixed payment
and quarterly payments adjusted for beneficiaries’ social risk.
Incorporate a prospectively projected administrative growth factor into a new three-way blend with national and regional growth rates to update an ACO’s historical benchmark for each performance year.
Reduce the cap on negative regional adjustments from -5 percent to -1.5 percent.
Account for prior shared savings in the generation of future financial benchmarks.
Provide increased shared savings opportunities for low-revenue ACOs in the Basic Track.
Add a health equity quality adjustment increase for ACOs with high quality performance by ACOs with high underserved populations.
Revise the beneficiary notification requirement from an annual requirement to once per agreement period.
Make changes to MIPS requirements for APMs.
Makes permanent the 8 percent risk standard for Advanced APMs, which was set to expire in 2024.
CMS RELEASES FINAL RULES ON SEVERAL HEALTH PAMENT PROGRAMS
In addition to releasing the final Medicare Physician Fee Schedule, CMS posted final Calendar Year (CY) 23 rules for hospital outpatient, home health, and renal disease. Highlights of the rules include:
Hospital Outpatient – A 3.8 percent payment rate update for hospital outpatient and ambulatory surgical center payment
Conditions of participation, payment rates, and Medicare enrollment requirements for newly designated Rural Emergency Hospitals.
Payment for 340B drugs at average sale price plus 6 percent as required by the U.S. Supreme Court’s decision in American Hospital Association v. Becerra. The agency will address
payments from 2018–2022 in future rulemaking prior to the CY 2024 outpatient proposed rule.
Home Health – An aggregate increase in payments of 0.7 percent, or $125 million compared to CY 2022
Payment cuts resulting from legislative changes to the payment system in 2018 will continue to be phased in over multiple years.
Home health agencies will begin reporting telehealth data so that CMS can better track the social determinants of beneficiaries who receive remote patient services.
CMS TESTING WEB MODE FOR CAHPS
CMS is conducting a field test of web mode for the Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey with MSSP ACOs. RAND began outreach to ACOs randomly selected to participate on
October 25. If you have been selected for this test, please share your feedback by emailing us at advocacy@naacos.com.
YEAR-END OUTLOOK
With just two months left in the year, there are several important deadlines NAACOS is tracking.
Regulatory
Congressional
Early November—CMS to release final payment rules for Medicare physician, hospital outpatient, and home health
November 13—Deadline for HHS to give 60-day notice about the expiration of COVID-19 PHE
November 17 – Final application dispositions for MSSP PY 2023 applicants
November 18 — ACO REACH Deadline to enter provider-level beneficiary enhancements and incentives for 2023
November/December— CMS to release final methodology for MA risk adjustment audits and possible early review of CY24 MA growth rates
December 23 — Deadline to sign new 2023 Participation Agreements
November 8— Election Day
November 14—Congress scheduled to reconvene for the lame duck session
Early December—Runoff elections if necessary
December 16—Expiration of current government funding and most likely deadline for Congress to consider a Medicare payment package which could include an extension of
the 5 percent APM incentive
December 21— Last day the 117th Congress is scheduled to be in session
December 31—Scheduled expiration of 5 percent APM incentive payment
January 3— Beginning of 118th Congress
EDUCATION OPPORTUNITIES
ATTEND NAACOS’ ANNUAL MEETING OF ACO MEMBERS
Join NAACOS leaders on November 15 from 3:00–4:00pm ET for our annual meeting of members. This is an excellent
opportunity to learn about your membership association and its initiatives to support the ACO community. The meeting will include reports from NAACOS board members and staff on ACO policy, our advocacy on
behalf of ACOs, new and ongoing educational activities, as well as the board’s strategic direction for NAACOS future. There will be ample time for questions. We look forward to your participation in this
webinar! Please note, this meeting is for employees of ACO members only.
NAACOS MEDICAID LEARNING LAB VIRTUAL SESSIONS BEGIN DECEMBER 2
If you would like to learn more about Medicaid contracting and patient management, don’t miss our next Learning Lab series! The virtual meetings in this series begin on December 2 and will continue in monthly
90-minute sessions over the next 12-to-15 months. The Learning Lab will provide content on value-based care models to support your contracted populations and networks, various Medicaid models throughout the
states, workflow options for value-based care related to primary care, social determinants of health, behavioral health, and high needs people, plus how to improve quality in the Medicaid population, and how
to enhance patient engagement in the Medicaid population. Sign-up today!
RESERVE YOUR SPOT FOR THE WINTER BOOT CAMP IN ORLANDO
Join us at the Marriott Orlando Airport Lakeside, February 9–10, 2023, for the Winter Boot Camp. The boot camp will provide
expert insight into the core competencies for ACOs. Faculty from top-performing ACOs will present clinical and operational strategies for success in any value-based care model. Participants will learn about
clinical improvement models, their outcomes, and implementation tips and tricks. The format will include presentations by clinical and operational leaders in accountable care, along with case studies, and
peer-to-peer learning. Boot camp topics have been announced and the full agenda is set to come in the upcoming weeks. This boot camp will only be offered in person. There will be no virtual option. Boot camps
are not open to business partners. Space is limited to 100 people. Register NOW!
NOT TOO LATE TO SIGN UP FOR AFFINITY GROUPS
Registration for new participants is open for NAACOS Virtual Affinity Groups! These virtual peer-to-peer opportunities provide a forum for members to meet and discuss hot topics, network with peers, and
exchange ideas. The Quality Affinity Group meets today, and the Data and Analytics Group meets November 9 from 3:00–4:00 pm. A meeting link will be provided when you sign up for each group and will work for
all future meetings. Please make sure to add the appointments to your calendars for these dates!
CALLING ACOS WITH HIGH-ACUITY POPULATIONS
Is your ACO high acuity or manages a large patient population from the post-acute or long-term care space? If you answered yes and you would like to have a peer-to-peer discussion about patient management
options, join the NAACOS High-Acuity Patient Management call on November 10 at 1:00 pm ET. Kristen Krzyzewski from LTC ACO will kick off this one-hour discussion to brainstorm on the unique needs of this type
of ACO. Sign up to join this event!
MEMBER RESOURCES
POST-ACUTE CARE MANAGEMENT RESOURCES IN REVIEW
We get a lot of questions on what ACOs are doing in the post-acute management space, from implementing waivers and innovative workflows to how to analyze data. The NAACOS archies are a treasure trove when it
comes to this and other care management topics. Find your ACO’s data in the NAACOS BCAPA reports brought to you by our Institute for
accountable care. The access request is easy if you don’t already have it! There are also several recording and slides in the Webinar on demand and conference archives. Examples include our recent webinar on
Managing Patient Complexity and Caseload Capacity, and slides from past
conferences including The Principles of Partnerships and
Building an ACO Post-Acute Network.
Want to learn more? Join us February 8–9 at the NAACOS Winter Boot Camp for some time to take a deep dive into ACO clinical and operations
transformation effort!
NAACOS UPDATES BCAPA REPORTS FOR MEMBERS
Comparing standardized beneficiary spending and utilization measures across is critical for MSSP ACOs to achieve better patient care and smarter spending. To help members get an accurate picture of how their
ACOs are performing relative to peers, we continuously improve the data quality and timeliness of the NAACOS
Benchmarking Comparison and Performance Analysis (BCAPA) web-based reporting tool. The latest BCAPA report with data through 2021 is now available
and allows ACOs to compare their performance with national and state ACO peer groups on Part A and Part B beneficiary spending and utilization measures. The web-based tool allows users to navigate across
years, ACO beneficiary categories, and comparison groups. Users can select wage standardized or unadjusted comparisons, and reports are easily exported to Excel.
Download your report today!
WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE
The U.S. Government Accountability Office (GAO) announced the appointment of two new members to the
Physician-Focused Payment Model Technical Advisory Committee (PTAC), the independent federal advisory
committee that reviews physician payment models and makes recommendations to HHS. The two new members are Lindsay Botsford, MD, MBA, CMQ, FAAFP, Market Medical Director with One Medical, and James
Walton, DO, MBA, FACP, President and CEO for Genesis Physicians Group.
The Medicare Payment Advisory Commission (MedPAC) will hold public meetings on November 3 and 4. The commissioners will discuss Medicare quality measures, payments for primary care, alignment of
fee-for-service payments, post-acute care payment options, supporting safety net hospitals, and standardizing MA benefits. The
full agenda is available.
A Health Affairs Forefront piece
analyzed the 2021 MSSP performance results
, highlighting ACOs serving greater proportions of beneficiaries dually eligible for Medicare and Medicaid and those with more safety net providers were able to be successful and achieve greater
shared savings than other ACOs.
Center for American Progress published recommendations on how to improve value-based care in
Medicare—fewer alternative payment models and mandatory participation.
