Newsletter for Members
and Partners
September 10, 2020
Table of Contents
We Want to See Your Smiling Face at Our Conference!
NAACOS Opens Virtual Exhibit Hall for Conference
Congressional Returns for Pre-Election Sprint
CMS Clarifies Quality Scoring Proposal in MPFS Rule
CMMI Releases Direct Contracting’s Implementation Period Details
Take action: Tell Congress To Address Advanced APM Bonus
Inpatient Hospital Payment Rule Finalized by CMS
Get Ready to Tout Your 2019 Performance Results Locally
Primary Care First Financial Details Released
MSSP’s Change Request Deadline Approaching
Beneficiary Voluntary Alignment Deadline Approaching for 2021
CMS Web Interface API: Now Available on QPP Website
MedPAC Discusses Tider telehealth Use Within APMs
CMS Updates COVID-19’s Impact on Medicare Utilization
Don’t Forget to Access NAACOS Member Resources
New CMS Provider Engagement Toolkit Available

WE WANT TO SEE YOUR SMILING FACE AT OUR CONFERENCE!
Even if it is over the computer…

We hope that you will join our Fall 2020 Virtual Conference coming up in just a couple of weeks. We are hard at work with speakers and staff to make this a robust conference full of information that you will need going forward. We will have content on direct contracting, COVID-19, PY2019 results, and more. If you are having trouble convincing your organization that you should attend, let us know and we can help you plead your case! Not only do you get access to every live session (there is nothing held concurrently while we are virtual!), but you also have access to the recordings for six months following the conference. On those days you just have to be in a meeting or have other tasks that need to be completed, you won’t miss anything! And we have built in networking time via Zoom that will be like our in-person peer-to-peer exchanges and have a virtual exhibit hall for all of your vendor needs. We want to make this conference as valuable to you as our in-person meetings, and we want to see you all there.

Some of our highlighted sessions include the Administration’s Policy on Value-Based Care with CMMI Director Brad Smith; Transforming the Health Care System with Dr. Don Berwick; Health Care Post-COVID with Dr. Mark McClellan; and our ever popular CMS TownHall with John Pilotte and Amy Bassano. View the full agenda with dates and times of the sessions!

Register Today! If you have any questions, please contact Emily Perron or email us.

NAACOS OPENS VIRTUAL EXHIBIT HALL FOR CONFERENCE
We are excited to announce that the NAACOS Fall 2020 Virtual Exhibit Hall is now open and will be open through October 2 for all conference registrants. Learn about the products and services our business partners have to offer you and your ACO. You can chat, enjoy live demos from select business partners, and even enter raffles for great prizes!

Are you a Business Partner of NAACOS and haven’t signed up for the exhibitor hall? It’s not too late! The virtual exhibit hall is complementary to all business partners in good standing. Features include virtual meet-ups, raffles, product photos, and MUCH more! Make sure you get your application in TODAY!


CONGRESS RETURNS FOR PRE-ELECTION SPRINT
Lawmakers began returning to Washington this week with a number of outstanding health care issues to address before the November elections. On September 8, Senate Republicans released a “skinny” COVID-19 relief package that includes liability protections, creates a second round of small business loans, and provides funding for testing, vaccines, and schools. Although a procedural vote scheduled for this week is likely to fail, Senate Majority Leader Mitch McConnell (R-KY) plans to use the package to re-start negotiations with Congressional Democrats. Negotiations are expected to continue through September on both a relief package as well as legislation to extend government funding beyond the current September 30 deadline. Lawmakers are also beginning to line up priorities for an end-of-year lame duck session of Congress, with House and Senate committee leaders continuing to look for a path forward on big ticket items like drug pricing and surprise medical billing.

CMS CLARIFIES QUALITY SCORING IN MPFS RULE
CMS has proposed substantial changes in the way Medicare Shared Savings Program (MSSP) ACOs would be evaluated on quality in both the MSSP and the Merit-based Incentive Payment System (MIPS) in the recently released proposed 2021 Medicare Physician Fee Schedule (MPFS) Rule. In an email to NAACOS, CMS staff recently clarified how the proposed approach to quality scoring will be calculated. According to CMS, “The score is calculated using the ACOs performance on all six measures in the Advanced Payment Model (APM) Performance Pathway (APP), plus any bonus and quality improvement points earned. This final score must meet or exceed the 40th percentile across all MIPS quality performance category scores.” This score would also be used to provide a quality score for ACOs subject to MIPS. Learn more about CMS’s proposed changes to the way MSSP quality is evaluated in our MPFS Rule analysis.

CMMI RELEASES DIRECT CONTRACTING’S IMPLEMENTATION PERIOD DETAILS
A draft copy of the Implementation Period Participation Agreement was sent out to Direct Contracting Entities this week. The CMS Innovation Center says this version will look very similar to the final version. Signed documents are due on September 27 for the Implementation Period that starts on October 1. A webinar to discuss the model’s long-awaited financial methodology is scheduled for September 16 at 10:30 am ET.

NAACOS is hosting an Implementation Period Learning Discussion at 2:00 pm ET on September 18. This will be an opportunity for Direct Contracting Entities (DCEs) that are planning to participate in the Implementation Period to share feedback, questions, concerns, or points of interest on the model with fellow DCEs. This collaborative discussion will provide a forum for shared learning, and we request that you send questions or requested conversation topics in advance to directcontracting@naacos.com. We will also use this forum to solicit initial reactions to and questions about the financial methodology, which is expected to be released by then. That feedback will help us prepare a more in-depth future discussion. Register Now!

TAKE ACTION: TELL CONGRESS TO ADDRESS ADVANCED APM BONUS
As Congress gears up for its pre-election work, NAACOS is encouraging its members to write their elected representatives urging them to address rising thresholds to achieve Advanced APM participation bonuses in 2021. Right now, thresholds to secure incentives payments are set to increase to unrealistic levels in 2021, and it threatens to derail our health industry’s move to support value-based payment. To get you started, NAACOS has drafted a letter, which should be personalized, to share how your ACO would benefit from the legislation. You must provide your address and contract information on the first page to be taken to the letter. Don’t forget to include your organization’s name at the end.

Welcome New Business Partner

Trella Health
Built on Medicare’s most recent and complete set of claims data for more than 60M patients, Trella Health’s analytics offer insights across the patient care continuum so you can thrive in value-based care.

trellahealth.com
INPATIENT HOSPITAL PAYMENT RULE FINALIZED BY CMS
CMS recently finalized the 2021 Medicare Hospital Inpatient Prospective Payment System rule and will start using Medicare Advantage rates to set payment rates for traditional Medicare starting in 2024. In the final rule, the agency said it would begin collecting hospitals’ median payer-specific negotiated charges for Medicare Advantage organizations in 2021. This data would inform a new market-based methodology to set the Medicare Severity-Diagnosis Related Group (MS-DRG) relative weights, that are used in determining Medicare payment rates for inpatient hospital stays. For next year, CMS estimates that hospital inpatient payment rates will increase by roughly 2.9 percent before various quality improvement programs, like for readmission penalties, take effect. CMS has released a fact sheet that summarizes the changes.

GET READY TO TOUT YOUR 2019 PERFORMANCE RESULTS LOCALLY
As CMS prepares to lift the embargo on ACOs’ 2019 performance results, NAACOS is trying to help ACOs spread news about these results within their communities. We have created a media kit for ACOs, including a press release template on 2019 savings, a tip sheet on sharing your news, and one-page background document on ACOs. We encourage you to share news about your 2019 savings, and we hope these resources will help you to do so. As ACOs’ aggregate savings increases, this is a wonderful opportunity to help educate your communities about your work to improve patient care and transform our nation’s healthcare system.

PRIMARY CARE FIRST FINANCIAL DETAILS RELEASED
The Center for Medicare and Medicaid Innovation Center (Innovation Center) recently released additional financial and attribution methodology details for the Primary Care First (PCF) Model. The model, set to begin in 2021, will run for six years and is designed to test whether changes to how Medicare pays for primary care can lead to reductions in acute hospital utilization and lower total cost of care, while preserving or improving quality. This methodology paper is referred to as volume one, and describes attribution, payment, and quality methodology details for the PCF component of Primary Care First. Volume two will later be released to describe details for the Seriously Ill Population (SIP) component of the model. NAACOS staff are currently reviewing the paper and will provide additional details in the near future. A NAACOS resource on PCF for ACOs, describing an overview of the PCF Model and its overlap with ACOs is available.


MSSP’S CHANGE REQUEST DEADLINE APPROACHING
MSSP ACOs have until noon ET on September 22 to make changes to the 2021 participation and correct deficiencies for previously submitted requests. ACOs still have time to “freeze” your participation on the Basic Track’s glidepath, elect an additional performance year if your contract is set to expire at the end of 2020, add or delete ACO participants, apply for a Skilled Nursing Facility Three-Day Stay Waiver, choose assignment methodology, and select a minimum savings rate (MSR)/minimum loss rate (MLR) if moving to a risk-based track. If an ACO no longer wants to make a change already submitted, you still have time to withdraw the change. The 22nd is also the deadline for MSSP ACOs interested in participating in Direct Contracting starting on April 1, 2021, to tell CMS of their intent to switch programs, since dual participation isn’t allowed. More information can be found on CMS’s website on MSSP application.

BENEFICIARY VOLUNTARY ALIGNMENT DEADLINE APPROACHING FOR 2021
The deadline for beneficiaries to select their primary clinician on MyMedicare.gov and be included in an ACO’s performance year (PY) 2021 prospective assignment list is September 30, 2020. Given the potential disruptions to assignment stemming from changes in utilization related to the COVID-19 pandemic, voluntary alignment may help ACOs maintain a more consistent assigned beneficiary population. Medicare beneficiaries are prospectively assigned to an ACO if the primary clinician to which they voluntarily align is an ACO clinician. Learn more about voluntary alignment by reviewing NAACOS Essentials for Voluntary Alignment.

CMS WEB INTERFACE API: NOW AVAILABLE ON QPP WEBSITE
CMS recently noted the agency will provide functionality on the Submissions Application Programming Interface (API) for the 2020 CMS Web Interface that will be accessible through the Quality Payment Program website. The API allows ACOs to programmatically submit and receive data via a predefined structured format. Immediate feedback is provided when ACOs submit CMS Web Interface data using the API. This will be accessible for preview in the Developer Preview Testing Environment to allow ACOs to submit and receive data via the API using a dataset provided containing mock patients. More information is available here. For questions, contact the Quality Payment Program at QPP@cms.hhs.gov.

Welcome New Associate ACO Members

Federal Urban Health Network – Plymouth, MA

Iora Health – Boston, MA
MEDPAC DISCUSSES WIDER TELEHEALTH USE WITHIN APMS
The Medicare Payment Advisory Commission (MedPAC), which makes recommendations on Medicare payment policy, is suggesting that CMS allow more flexibilities for telehealth coverage within Advanced APMs. MedPAC commissioners noted that expansion of telehealth within fee-for-service or non-risk bearing APMs would necessitate significant guardrails to prevent overuse. MedPAC’s discussion around telehealth’s future, which occurred during the commission’s September meeting, falls mostly in line with what NAACOS has been advocating for. A key difference is that NAACOS believes all ACOs, regardless of risk level or choice of attribution, should be allowed greater flexibilities to use telehealth. NAACOS will continue to track MedPAC’s work on this issue and advocate for ACOs on Capitol Hill. If ACOs are willing to share their experiences with using telehealth or have utilization data they are willing to share, please email advocacy@naacos.com because your stories and data would be helpful in our advocacy.

CMS UPDATES COVID-19’S IMPACT ON MEDICARE UTILIZATION
The rate of COVID-19 cases and hospitalizations among Medicare beneficiaries grew about 40 percent and 33 percent respectively between July and August to about 1,200 cases and 338 cases per 100,000 patients, according to recently released CMS data. Cases and hospitalizations reached a low in late June but have been increasing since. CMS says fee-for-service spending among COVID-19 hospitalizations averaged just over $25,000 per hospitalization. More information on Medicare’s COVID-19 data is available.

DON’T FORGET TO ACCESS NAACOS MEMBER RESOURCES
NAACOS has a number of resources designed to help ACOs understand critical policy and program changes. As a member of NAACOS you have free access to all member resources, access these tools today! Recently released resources include:
  • NAACOS Analysis of the 2021 Proposed MPFS Rule (updated September 10th with key clarifications from CMS)
  • NAACOS Summary of the May 8 Interim Final Rule with Comment making further changes to MSSP policies for COVID-19
  • NAACOS Review of the CMS April 6 Interim Final Rule with Comment Activating MSSP Extreme Circumstances Policy for ACOs in 2020 as a result of the COVID-19 pandemic
  • NAACOS has developed a COVID-19 and ACOs fact sheet
  • NAACOS has also developed a Telehealth FAQ to assist ACOs using telehealth services during the COVID-19 crisis
NEW CMS PROVIDER ENGAGEMENT TOOLKIT AVAILABLE
CMS has created a new ACO Provider Engagement Toolkit. The toolkit describes strategies used by ACOs to engage providers in quality improvement and other ACO activities. This is the third toolkit in a series CMS has offered and brings together insights from CMS-sponsored learning system events and focus groups conducted with ACOs by CMS. CMS aims to educate the general public through these toolkits about strategies used by ACOs to provide value-based care and to educate the general public about these efforts.