NAACOS UPDATES BENCHMARKING TOOL FOR MEMBERS To help Medicare Shared Savings Program (MSSP) ACO members get an accurate picture of how their ACOs are performing relative to peers, we continuously work to improve the contents and timeliness of the NAACOS Benchmarking Comparison and Performance Analysis (BCAPA) reporting tool. The latest BCAPA report is now available in a web-based platform. This tool allows you to compare your ACO’s performance to various peer groups on standardized Part A and Part B spending and utilization measures; reports with data from customized peer groups are also available for a fee. The new tool also allows users to navigate easily between report views and download report views to Excel with one click. Business partners will be able to purchase access to BCAPA data in early October.
FALL CONFERENCE NOW UNDERWAY Our Fall 2020 Conference began this week with expert insight into new models from CMMI’s Brad Smith, a look at health reform’s future from former Biden-Sanders Advisor Don Berwick, and sessions on managing risk and new rules for data sharing.
Next week’s line-up includes current and former MedPAC commissioners, town hall-style Q&A with CMS’s Bassano and Pilotte, five panels on critical ACOS issues like chronic care, rural health, Medicaid opportunities, and policy updates.
It’s not too late to join us! Register now and receive $200 off the prevailing rate! **Use discount code LastChance200**. This code may not be combined with any other discount codes and may not be applied to prior registrations for the fall virtual conference. All registrations include six months of access to the recordings of all sessions.
CONGRESS ANNOUNCES SHORT-TERM FUNDING DEAL Congressional leaders and the White House reached a bipartisan agreement this week on legislation that will temporarily extend government funding through December 11. The agreement also includes a temporary extension of a number of expiring Medicare and Medicaid programs and extends the repayment period and reduces the interest rate for Medicare providers who participated in the accelerated and advance payment program. The President is expected to sign the funding bill before the end of the fiscal year on September 30.
UPHEAVAL FOLLOWING JUSTICE GINSBURG’S DEATH CAUSES UNCERTAINTY Following the death of U.S. Supreme Court Justice Ruth Bader Ginsburg, President Donald Trump plans to announce a nominee as soon as Saturday. Senate Majority Leader Mitch McConnell (R-KY) has said the Senate will move forward with the confirmation process once a nominee is selected. The confirmation process is expected to be contentious. The outcome could also have an immediate impact on health care with the Supreme Court scheduled to hear arguments in the legal challenge to the Affordable Care Act (ACA) in November.
CMS RELEASES 2019 MSSP RESULTS The Medicare Shared Savings Program had another record year of savings while continuing to provide high-quality care, as shown by data on 2019 performance recently released by the Centers for Medicare & Medicaid Services (CMS). The MSSP served 11.2 million beneficiaries in 2019, collectively saving Medicare $2.6 billion and $1.2 billion after accounting for shared savings bonuses and collecting shared loss payments. ACOs earned nearly $1.5 billion in shared savings payments, and NAACOS issued a press release touting these notable results. We congratulate ACOs on their hard work and success!
ACTION ALERT: URGE YOUR MEMBER OF CONGRESS AND CMS TO SUPPORT ACOS NAACOS continues to urge its members to write their elected representatives and ask them to address rising thresholds to achieve Advanced Alternative Payment Model (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. Separately, we’re asking ACOs to write CMS to not move forward with sweeping changes to how ACOs and other APMs are assessed on quality.
Visit our Take Action page to access draft letters on either issue. Before submission, letters should be reviewed and personalized to share how the issue affects your ACO. 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 ACO Members
Genuine Health – Coral Gables, FL
NAACOS PROPOSED 2021 MPFS RULE COMMENTS NOW AVAILABLE NAACOS has submitted comments in response to the proposed 2021 Medicare Physician Fee Schedule (MPFS) rule. Comments are due to CMS by October 5 and NAACOS strongly recommends ACOs share their feedback on the proposals with CMS. In particular, CMS is proposing significant changes to the way ACOs are evaluated on quality in the MSSP and Merit-Based Incentive Payment System (MIPS); these changes are summarized in our NAACOS MPFS rule analysis. As noted in the article above, NAACOS has also drafted a brief template letter for ACOs to customize and send to CMS urging the agency to not move forward with such drastic changes to the way ACOs report and are assessed on quality at this time. Send your letter to CMS and make your ACO’s voice heard! We also encourage members to use language from our full comment letter in their own organization’s letters to CMS.
CMS DISTRIBUTES ADVANCED APM BONUSES CMS recently issued Advanced APM bonuses to those that qualified based on 2018 performance. The bonus amounts are based on claims from 2019, and these bonuses are not considered expenditures for ACO program evaluations. Despite NAACOS advocacy to pay the bonuses directly to ACOs, CMS continues to pay the bonus to the Tax ID (TIN) associated with the participation in the ACO, or other Advanced APM entity. More information is available on this CMS webpage.
SHARING 2019 MSSP RESULTS NAACOS is trying to help ACOs spread news about their positive 2019 performance 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 hope these resources will help you to do so. ACOs do not need to submit their press releases to CMS for review and approval. ACOs are also required to publicly report performance results on a designated webpage by October 14 and must use CMS’s updated Public Reporting Template.
LONG-AWAITED FINANCIAL SPECIFICATIONS FOR DIRECT CONTRACTING PUBLISHED NAACOS is continuing to review newly released financial specification papers on Direct Contracting with plans to have more educational events and resources soon. The long-awaited details were released on September 16 and cover use of a new Rate Book, risk adjustment, and capitation options. All papers and slides from a September 18 CMS webinar are posted on the NAACOS site. Share feedback and reactions with DirectContracting@naacos.com.
Participant and preferred provider lists are due on September 28. CMS should have notified Direct Contracting Entities accepted to participate in Performance Year 1 by now, and signed participation agreements for the implementation period, which starts next month, are also due soon.
NOTICE OF FUNDING OPPORTUNITY FOR CHART MODEL ANNOUNCED CMS has posted the Notice of Funding Opportunity for the Community Transformation Track of the Innovation Center’s recently announced Community Health Assessment and Rural Transformation (CHART) Model. The Innovation Center will select up to 15 organizations to receive funding to work with participating healthcare providers, the state Medicaid agency and other community-based partners to oversee and execute a plan that redesigns the care delivery system of a community. Applications are due by February 16, 2021. The CHART Model will also hold an ACO Transformation Track that will provide start-up money for rural-focused ACOs to join the MSSP. Applications for that will be available early next year.
NAACOS SURVEY SHOWS VALUE, CONCERN AROUND ADVANCED APM BONUS More than 90 percent of respondents to a recent NAACOS survey reported they are concerned they won’t meet thresholds to earn Advanced APM bonuses, which jump to unrealistic levels in 2021. That concern is validated by the survey’s data, which shows that 96 percent of the 216 ACO respondents would not meet the 2021 thresholds based on their performance in 2020. NAACOS is calling on Congress to take swift action to address the Qualifying APM Participant (QP) thresholds and help stabilize incentives for participating in Advanced APMs.
CMMI EVALUATION FINDS ACO INVESTMENT MODEL A SUCCESS NAACOS is pleased to see the CMS Innovation Center release the final evaluation of the ACO Investment Model, which showed three years of sustained success. The model was successful in reducing total Medicare spending without decreasing the quality of care provided. Most of the advanced payments have been recouped through shared savings while most participants either stayed in MSSP or joined an existing MSSP ACO.
INNOVATION CENTER MOVES FORWARD WITH APM IMPLEMENTATION The CMS Innovation Center plans to start two mandatory, condition-specific models in January 2021. The End-Stage Renal Disease (ESRD) Treatment Choices (ETC) Model and Radiation Oncology (RO) Model were first proposed in 2019, and NAACOS submitted comments in response to a proposed rule on those. Participation will be mandatory for about 30 percent of adult ESRD beneficiaries in all 50 states and about 30 percent of all eligible Medicare fee-for-service (FFS) radiotherapy episodes nationally. CMS has posted fact sheets on either the ESRD Choices ETC Model or the Radiation Oncology RO Model. The Innovation Center also announced that the Emergency Triage, Treat, and Transport (ET3) Model, which tests paying ambulance services for treating patients at a scene, transporting to non-emergency department, or treating via telemedicine, will begin in January 1, 2021, a delay of its planned May 2020 start due to the COVID-19 pandemic.
NAACOS URGES UNILATERAL CHANGE TO NEXT GEN NAACOS recently sent a letter to the Innovation Center requesting it not move forward with a unilateral change to the trend rate used for the Next Generation (Next Gen) ACO Model. While NAACOS supports providing protections from COVID-19 to Next Gen ACOs through an optional amendment, we are disappointed CMS is also implementing unilateral changes for ACOs that would prefer to maintain their agreed upon risk levels and prospective benchmarks for 2020.
BPCI-A MODEL CONTRACT UPDATES RELEASED The Innovation Center recently shared updates to contracts for Performance Year (PY) 2021 (Model Year 4) with current Bundled Payments for Care Improvement-Advanced (BPIC-A) participants. These updates are significant and include changes to the trend adjustments and require the selection of an episode service line group instead of a single episode, among others. The email to participants indicates additional changes may be included in the upcoming participation agreement and updated model specification documents.
CMS RELEASES MEDICARE ADVANTAGE RATE NOTICE EARLY CMS would fully phase in a new risk adjustment model in Medicare Advantage by 2022 under a recently published Advanced Notice. The new model would use diagnoses solely from encounter data submitted by healthcare providers about patients’ medical conditions and treatment. CMS usually publishes such notices in the winter but issued the next notice early to help health plans implement proposed changes. Other Medicare Advantage payment policies are expected in April 2021. CMS issued a fact sheet and press release on the changes.
CMS ISSUES NEW ROADMAP FOR STATES TO ACCELERATE ADOPTION CMS recently issued guidance to state Medicaid directors in order to advance adoption of value-based care strategies across their health care systems and align provider incentives across payers. The guidance includes lessons learned from early state and federal value-based care reforms as well as a toolkit for states to adopt reforms within their programs. Examples of payment models included are advanced payment methodologies under FFS, bundled payments, and total cost of care models. CMS has provided a factsheet for more information.
