NAACOS Newsletter for Members and Partners November 18, 2021

Table of Contents
Winter Boot Camp Registration Now Open!
NAACOS Analysis of 2022 MPFS Rule Now Available
MSSP Extreme and Uncontrollable Circumstances Policy for 2021
Congress Mulls Continued Work on BBB
Opportunity to Join an AWV Study with IAC
NAACOS AWV Webinar Now Available On-Demand
NAACOS’ Next Direct Contracting Learning Discussion Is Tomorrow
New Date for Webinar on Care Delivery Models
Voluntary Termination Requires 30 Days’ Notice
Innovation Center Implements First Health Equity Model Changes
MedPAC Discusses ACO Benchmarking
OMB Publishes Summary of Responses to RFI on Advancing Equity
NAACOS Joins Leaders in Primary Care Summit

WINTER BOOT CAMP REGISTRATION IS NOW OPEN!
Join us February 7–8, 2022, at the Marriott Orlando Airport Lakeside for the NAACOS Winter 2022 Boot Camp, providing expert insight into core competencies for ACOs and DCEs. Boot camp faculty will present essential resources and policy updates, as well as basics on successful care management and resource allocation. Faculty will also facilitate learning groups for ACOs, DCEs, and those interested in either model. These learning groups will drill down into issues such as using data, claims and reports, as well as operationalizing care management tools and managing waivers. The format for this boot camp will include presentations by leaders in accountable care, case studies, hands-on exercises, and peer-to-peer learning. After completing two full days, boot camp attendees will leave with actionable knowledge to enhance the most critical operations within their ACO or DCE. A detailed schedule and agenda are available! Register today.

Registration Rates:
ACO Member – $1,095 per person
ACO Non-Member – $1,395 per person
ACO Member Group Rate – $4,500 for up to five individuals (To register a group rate, please contact Emily Perron)

**This boot camp will be held as an in-person event without a virtual option. Boot camps are not open to business partners. Space is limited to 110 people. Proof of COVID-19 vaccination is required to attend. **

NAACOS ANALYSIS OF 2022 MPFS RULE NOW AVAILABLE
NAACOS has developed an in-depth analysis of the final 2022 Medicare Physician Fee Schedule (MPFS) Rule to help members understand key ACO changes in the regulation. The analysis reviews quality changes for Medicare Shared Savings Program (MSSP) ACOs finalized in the rule, key payment policies to be aware of, and Quality Payment Program (QPP) updates for 2022, among other issues. Members can view an on-demand version of our recent webinar reviewing these policies.

MSSP EXTREME AND UNCONTROLLABLE CIRCUMSTANCES POLICY FOR 2021
The Health and Human Services Secretary’s declaration of the COVID-19 Public Health Emergency (PHE) in January 2020 triggered the MSSP’s Extreme and Uncontrollable Circumstances Policy. The extreme and uncontrollable circumstance of the COVID-19 PHE will apply nationwide for the duration of the COVID-19 PHE. There is no application process or action ACOs need to take; the policy is in effect for the duration of the PHE. Per the Extreme and Uncontrollable Circumstances Policy, during this time shared losses will be mitigated for all ACOs participating in a performance-based risk track (including Track 2; the Enhanced Track; Levels C, D, and E of the Basic Track; and the Track 1+ Model) based on the length of the COVID-19 PHE. The PHE covers the full year for 2021 (January through December 2021). Therefore, any shared losses an ACO incurs for Performance Year (PY) 2021 would be reduced completely, and the ACO would not owe any shared losses. In addition, the Extreme and Uncontrollable Circumstances Policy provides ACOs with the higher of their own quality score or the quality performance standard score (the 30th percentile of the Merit-based Incentive Payment System quality performance category scores for PY 2021).

CONGRESS MULLS CONTINUED WORK ON BBB
Following the Congressional Recess last week, Capitol Hill now turns back to consideration of the Build Back Better (“BBB”) spending bill (H.R. 5376). House Democrats say that chamber may vote on the measure as soon as this week after failing to garner the support it needed to pass earlier this month alongside the $1.2 trillion bipartisan Infrastructure Investment and Jobs Act (H.R. 3684). The Congressional Budget Office (CBO) has indicated that it could have a budget estimate for BBB prepared by later this week—a key hold up for moderate House Democrats. Meanwhile, the Senate is likely to move forward with the Fiscal Year 2022 National Defense Authorization Act (H.R. 4350) this week. If the House does pass the BBB, the Senate will then turn to consideration of the BBB although a timeline and prospects for passage remain unclear. The White House held a signing ceremony for the infrastructure bill on Monday with stakeholders, administration officials, and members of Congress joining President Joe Biden as he signed the key achievement into law. President Biden has refocused his messaging on the positive impact he believes the infrastructure bill will have on rising inflation and supply chain problems.


OPPORTUNITY TO JOIN AN AWV STUDY WITH IAC
The Institute for Accountable Care is seeking ACOs interested in joining its proposal to the Patient Centered Outcomes Research Institute (PCORI) to study the clinical effectiveness of standard annual wellness visits (AWVs) compared with AWVs augmented with GRACE (a validated advanced primary care model). Participating ACOs will get access to a standardized AWV protocol as well as training and support in the GRACE model, including access to dozens of standardized protocols that can be implemented with high-need older adults to address a range of geriatric issues. In addition, sites will receive funding to offset the costs of participating, including funds for a half-time FTE study coordinator.

During the study, ACOs will first join a learning collaborative for 12 months. After the pilot and training phase, ACOs who decide to go on to the study phase will be asked to randomize primary care practices to use of a structured AWV or an AWV augmented with GRACE. During the study, ACOs will be asked to provide data and collect information about patient and caregiver experience. If you are interested, please reach out to Jennifer Perloff or Sam Sobel at the Institute for Accountable Care.

NAACOS AWV WEBINAR NOW AVAILABLE ON-DEMAND
NAACOS was excited to see more than 300 attendees on the November 10 webinar focusing on the operational and engagement efforts of ACOs who have been successful in implementing virtual AWVs. Presenters included: Stephanie Turner and Jennifer Lui, UNH Health Alliance ACO; Jasmin Eversley- Danso and Dr. Marianne Labarbera, Richmond Quality ACO; and Kaitlyn Huttman, Keystone ACO. Their presentations outline the operational aspects of engaging beneficiaries, implementation and workflow design for virtual visits, outcome data for completion, and advantages for completing AWVs virtually. NAACOS members can access the recording on-demand.

NAACOS’ NEXT DIRECT CONTRACTING LEARNING DISCUSSION IS TOMORROW
Please join NAACOS and fellow DCEs tomorrow at 2:00 pm ET for our next Direct Contracting Learning Discussion. The event is meant for DCEs that are participating in or planning to participate in the Global and Professional Direct Contracting Model to share your feedback, questions, concerns, and points of interest. This is intended to be a collaborative discussion and a forum for shared learning, and we ask that you come prepared to share your perspectives and react to issues at hand. The meeting will take place over Zoom (passcode: 711587). Advance registration is not required, and the meeting will be recorded and posted on our website for those unable to attend live. If you have issues you’d like to raise, please share them in advance with DirectContracting@naacos.com.

NEW DATE FOR WEBINAR ON CARE DELIVERY MODELS
December 16, 2021, from 2:00 to 3:00 pm ET
The Baby Boomer Generation has already begun to age into Medicare, and its number of beneficiaries is projected to increase to over 80 million — meaning more people than ever before will rely on the healthcare system. In turn, this new Medicare population will drastically shift the current care delivery models and drive higher demand for long-term care services. So how can ACOs and DCEs prepare for this new Medicare patient? Leading the consumerization of health care, this generation’s knowledge of and preferences about real-time access to healthcare data, aging, and quality of life are much different than their parents. During this presentation, we will discuss the importance in establishing new care delivery models and standardizing care within your post-acute network. Insights will also be provided into how post-acute data transparency will play an integral role in delivering the care and transparency that this new Medicare patient will require. Register today for this webinar sponsored by Real Time Medical Systems. This webinar is complimentary for NAACOS ACO and DCE members, but it is not open to Business Partners.

Speakers: Gina Markwell, LNHA, Director, Post-Acute and Transitional Care Triad HealthCare Network, and Phyllis Wojusik, RN, EVP, Health System Solution, Real Time Medical Systems


VOLUNTARY TERMINATION REQUIRES 30 DAYS’ NOTICE
ACOs choosing to voluntarily terminate their contracts must inform CMS with at least 30 days’ advance written notice, including the effective date of termination. ACO participants must also be notified of the decision to voluntarily terminate the MSSP agreement within this timeframe. As a reminder, this means ACOs must submit a termination notice on or before December 1st to choose a termination date effective on or before December 30th. ACOs that choose a termination effective date on or before December 30th are not financially reconciled for purposes of determining shared savings. ACOs participating in a two-sided track/level with a termination date after June 30th are financially reconciled and, therefore, liable for a prorated share of losses. If an ACO selects a termination date of December 31st, the ACO will be financially reconciled and may qualify to receive shared savings or be liable for losses, if applicable. For step-by-step instructions on how to submit a voluntary termination notice, review the ‘Submitting a Voluntary Termination Notice in ACO-MS’ tip sheet found in the Program Resources Section of the Knowledge Library Tab in the ACO-MS. This document also reviews all close-out procedures and other requirements for ACOs choosing to voluntarily terminate their agreements with CMS.

INNOVATION CENTER IMPLEMENTS FIRST HEALTH EQUITY MODEL CHANGES
Following the blueprint to address health equity set forth in its recently published “Strategy Refresh” white paper on October 29, the CMS Innovation Center released a final rule implementing changes to End-stage Renal Disease (ESRD) Treatment Choices (ETC) model. Changes to the model include rewarding ESRD facilities and clinicians that improve the home dialysis rate and kidney transplant rate for lower-income beneficiaries. The rule also provides model participants COVID relief by finalizing ESRD Quality Improvement Program (QIP) changes providing that no facility will receive a payment reduction under the ESRD QIP for the upcoming year. NAACOS expects to see similar health equity incentives in all the Innovation Center’s initiatives, including in the upcoming changes to the Direct Contracting model that we expect to see Spring 2022.

MEDPAC DISCUSSES ACO BENCHMARKING
In its continued discussion of ACOs and alternative payment models, the Medicare Payment Advisory Commission (MedPAC) is looking at possible recommendations around benchmarking policies. In a discussion at its November meeting, commissioners explored how to administratively set trend factors for ACOs to both create more savings for Medicare and set realistic benchmarks in the long-run. However, commissioners expressed concern if reaching such goals were possible if ACO programs remain voluntary. Commissioners offered few details on their thoughts about trending, such as a preference for regional versus national, prospective versus retrospective, gross domestic product versus Medicare spending. MedPAC makes recommendations on Medicare payment polices to CMS and Congress, and NAACOS will continue to monitor its monthly meetings and keep members apprised of any significant movement. Slides from the November discussion are online as is a transcript of the meeting.

OMB PUBLISHES SUMMARY OF RESPONSES TO RFI ON ADVANCING EQUITY
Earlier this year, NAACOS submitted comments in response to a broad request for information (RFI) issued by Office of Management and Budget (OMB) to solicit feedback on advancing equity through federal policies. In these comments, NAACOS recommended creating new opportunities and funding for ACOs to address health equity, ensuring quality reporting is thoughtfully designed and implemented, leveraging the ACO model to test telehealth expansions, and improving ACOs’ access to data needed for care coordination. Recently, OMB released a summary of responses to the RFI. Key takeaways from the responses include the importance of acknowledging intersectionality in policies that address equity, the underestimation by federal agencies of the volume, variety, and significance of barriers to accessing public services, the need for meaningful, long-term community engagement, as well as the need to “meet people where they are at” by providing flexibility in solutions. NAACOS continues to advocate for policy changes that support ACOs’ work to address health equity.


NAACOS JOINS LEADERS IN PRIMARY CARE SUMMIT
Last week, NAACOS joined the Primary Care Collaborative’s (PCC) working summit — From Crisis to Opportunity: Primary Care for All Communities. This was an important opportunity for diverse stakeholders to collaborate on efforts to implement primary care payment recommendations put forth by the National Academies of Sciences, Engineering, and Medicine (NASEM) in the recent report: Implementing High-Quality Primary Care. Primary care is the foundation of the accountable care model, as outlined in the Innovation Center’s recent strategy paper. NAACOS will continue to collaborate on efforts to strengthen primary care and transition our health system towards value-based care.