NAACOS Newsletter for Members and Partners November 19, 2020
| WINTER 2021 BOOT CAMP REGISTRATION NOW OPEN! Give your staff a leg up on building and maintaining successful programs in value-based care. Avoid travel cost and time away from the office and home by attending our virtual program January 26 – 27 from 11:00 am – 4:00 pm ET with deep dives into critical issues with small group discussions to ask questions pertaining to your model/track.
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CHECK OUT THE WEBINAR: DCE AND ACO TOOLKIT FOR TAKING RISK Did you miss last Friday’s webinar from Episource to help ACOs and newly formed DCEs? Don’t worry, you can catch it On-Demand now! Want to learn how to navigate the challenging healthcare landscape of today? How about successfully manage risk while improving patient outcomes? “DCE and ACO Toolkit for Taking Risk” is here for you. Stop over today! FINAL CHANCE TO PURCHASE NAACOS FALL CONFERENCE RECORDINGS! If you were unable to attend the recent virtual conference live, we are selling access to the archive of all sessions for $300 off the cost of the standard rate of the conference.
PRESIDENTIAL TRANSITION CONTINUES DESPITE DELAYS Although the formal transition has been delayed by the Government Services Administration (GSA) pending the outcome of election challenges, the Biden Transition Team is moving forward with an informal transition by naming former Vice Presidential Chief of Staff Ron Klain as White House Chief of Staff, launching a transition website, and establishing agency review teams that are beginning outreach to government officials and congressional offices. These review teams provide a preview of what officials will likely staff key agencies across the federal government. The transition team also announced the creation of a COVID-19 Task Force that will help shape the Biden Administration’s response and management plans for the pandemic. The task force is already coordinating with Congress on the incoming administration’s pandemic response plans, including strategizing plans for vaccine distribution. NAACOS BLOG: ACOS OUTPERFORM OTHER APMS Health Affairs on November 12 published a blog from NAACOS authors, including CEO Clif Gaus, that compared the relative performance of accountable care payment models to other non-ACO models. The data show that ACOs have outperformed other medical home and episodic-based payment models. The blog argues that policymakers need to recognize this disparity in Medicare and prioritize accountable care models over developing and fine-tuning other models. Too often, the myriad of alternative payment models (APMs) competes with each other, creating adverse incentives. NAACOS is urging the incoming Biden Administration to consider this evidence as the administration implements payment reform, and we suggest that ACOs are the best path forward. POST-ELECTION: LAWMAKERS RETURN FOR LAME DUCK SESSION Although President Donald Trump is mounting legal challenges in a number of states, former Vice President Joe Biden is the projected President-elect after media outlet projections show him securing 306 Electoral College votes. States will be certifying election results over the coming weeks. The Electoral College is scheduled to officially meet on December 14 to cast ballots. In the U.S. House of Representatives, Democrats maintain a slim majority after Republicans won a number of competitive elections. Control of the U.S. Senate will be determined by two runoff elections in Georgia on January 5. The runoff elections were triggered after no candidate reached the required 50 percent threshold for multi-candidate races. As states continue to certify election results across the country, lawmakers have returned for the lame duck session of the 116th Congress. Although congressional leaders have expressed interest in passing a COVID-19 package before the end of the year, it’s unclear if Republicans and Democrats will be able to reach an agreement. Lawmakers also have until December 11 to extend government funding and address expiring health programs. Congressional leaders have expressed a desire to pass a full fiscal year spending package, but another short-term extension is possible if a bipartisan agreement is not reached. There are also several Medicare reimbursement issues gaining the attention of lawmakers as possible additions to an end-of-year spending package. NAACOS is working closely with our stakeholder partners and congressional champions to request that lawmakers address rising Qualifying APM Participant (QP) thresholds and the rural glitch. SUPREME COURT CONSIDERS FUTURE OF ACA On November 10, the U.S. Supreme Court heard oral arguments in California v. Texas. Plaintiffs argued that the Affordable Care Act’s (ACA) individual mandate is not severable from the rest of the law, and therefore, the entire law is unconstitutional. During oral arguments, Chief Justice John Roberts and Justice Brett Kavanaugh expressed the view that the court could strike down the law’s individual mandate, while allowing the rest of the law to stand. NAACOS continues to closely follow this case since the Medicare Shared Savings Program (MSSP) and Center for Medicare and Medicaid Innovation (CMMI) were both established by the ACA. A decision in the case is expected in Spring or Summer 2021.  CMMI PUBLISHES FORMAL EVALUATIONS FOR TWO MODELS Two formal evaluations published this month on CMMI models showed improvements in quality and spending reductions. The Comprehensive End Stage Renal Disease (ESRD) Care Model reduced Medicare spending by $115 million or 1.5 percent over the first three years, but Medicare spending increased by a net of $57 million after accounting for shared savings payments. Spending reductions were driven primarily by a 4 percent drop in hospitalizations. More detail can be found in the summary or full report. The Comprehensive Care for Joint Replacement Model experienced a net savings of $61.6 million even after accounting for reconciliation payments. That’s about a 2 percent savings. The evaluation found quality was improved or maintained under the model. Savings were driven by decreases in institutional post-acute care use. More detail can be found in the summary or full report. LETTER ASKS CONGRESS TO FREEZE QP THRESHOLDS NAACOS joined 18 other leading healthcare organizations on a letter asking lawmakers to freeze the current thresholds to achieve the Advanced APM bonus at their 2020 levels. Ensuring the bonuses don’t increase to unrealistic levels next year remains NAACOS’s top legislative priority this year. A survey of ACOs from this fall found 96 percent would fall short of the increased 2021 thresholds based on 2020 data, and we continue to hear from member ACOs that this is a major concern. There is still an opportunity for Congress to address the thresholds in a year-end spending package that must pass on or before December 11. ACOs can visit the NAACOS Take Action page to write your elected representatives in Congress and ask them to address this issue. Q3 EXPENDITURE REPORTS NOW AVAILABLE MSSP ACOs should have received their third quarter expenditure and utilization report packages from CMS. This report package includes an Assignment List Report, Assignment Summary Report, Aggregate Expenditure/Utilization Report, Non-Claims Based Payment File, and 2020 Q2 Claims-Based Quality Measures Report. Packages were sent via the ACO-MS Data Hub, the SSP ACO Portal, and the MFT mailbox. CMS reminds ACOs that they can expect to be able to access their enhanced third quarter reports, which include more detailed summaries of assigned beneficiaries and quarterly spending, next week. CMMI DELAYS BENEFICIARY NOTIFICATION FOR DIRECT CONTRACTING CMMI has moved the deadline for Implementation Period Direct Contracting Entities to send their beneficiary notifications from November 30 to December 21. These notifications, which the Innovation Center must review before being released, should be sent to all beneficiaries found in the Implementation Period Alignment Report. QPP ADDS EDUCATIONAL RESOURCES ON 2020 WEB INTERFACE QUALITY REPORTING The Quality Payment Program (QPP) recently added a new resource, the 2020 CMS Web Interface Quick Start Guide, to assist Web Interface quality reporting for Performance Year (PY) 2020. The resource outlines quality measures and specification updates for 2020, as well as the reporting process. Please note this document is tailored to MIPS reporters selecting the Web Interface and therefore ACOs should refer to the MSSP and/or Next Generation Model (Next Gen) requirements and standards for quality reporting. CMS has also announced that the MIPS data submission window will open January 4, 2021 and will close on March 31, 2021. The MSSP and Next Gen Models have not yet announced specific reporting deadlines for ACOs reporting quality. For ACOs subject to MIPS, the Promoting Interoperability data submission process will take place during this January 4 to March 31 timeframe. DECEMBER 31 DEADLINE TO SUBMIT MIPS HARDSHIP EXCEPTION The deadline to submit a Merit-Based Incentive Payment System (MIPS) hardship exception application is December 31, 2020. Due to the COVID-19 Public Health Emergency (PHE), CMS is allowing ACOs to apply for reweighting of all MIPS performance categories. If the application is approved, this would provide the ACO and all its MIPS Eligible Clinicians (ECs) with a neutral MIPS score for PY 2020 (and a zero percent adjustment to corresponding MIPS payments in 2022). To be eligible for this hardship exception, 75 percent of the MIPS ECs in the APM Entity must qualify for reweighting in the MIPS Promoting Interoperability performance category. CMS notes they will not require documentation to be submitted with the application, however, ACOs should retain documentation of the circumstances supporting their application for their records in case of a future CMS audit. The application is available on the QPP website. Please note that this exception was proposed in the 2021 Medicare Physician Fee Schedule rule which has yet to be finalized. Therefore, the applications will only be considered should CMS finalize this policy when the final rule is released. More information is available on the CMS website. |