Newsletter for Members and Partners February 11, 2021

Table of Contents
Congress Advances COVID Relief Amid Impeachment Trial
NAACOS Urges CMS to Change 2020 MSSP Quality Scoring
2020 ACO Quality Reporting Continues
BCDA Data Now at Parity with CCLFS
Registration Still Open for NAACOS Direct Contracting Learning Discussion
Take Advantage of Recent NAACOS Resources
Primary Care First Model Cohort 2 Eligibility Changes
New CMS Issue Brief on Care Management Services
NAACOS All-Payer Combination Option Webinar Available On-Demand

CONGRESS ADVANCES COVID RELIEF AMID IMPEACHMENT TRIAL
While the second impeachment trial of former President Trump continues to dominate headlines in Washington, lawmakers are working behind the scenes on a number of health priorities. Congress passed a budget resolution on February 5, 2021, including specific directives for congressional committees to draft a COVID-19 stimulus package. Committees are working on that language now, and it is expected that the package will largely mirror President Biden’s $1.9 trillion COVID Relief Plan, and it will include funding for the Provider Relief Fund, vaccine distribution, economic stimulus, and other measures. The package will proceed under the reconciliation process, requiring strict adherence to rules on budgetary impact, and it is likely to pass along party lines. Senate hearings for Presidential appointees also continued this week as Office of Management and Budget (OMB) Director nominee Neera Tanden appeared before the Senate Homeland Security and Government Affairs Committee and the Budget Committee. Senate leadership has conveyed that hearings for President Biden’s nominees will continue apace as the Senate also focuses on the impeachment trial.

NAACOS URGES CMS TO CHANGE 2020 MSSP QUALITY SCORING
A recent NAACOS survey of MSSP ACOs shows many are concerned about the effect of the COVID-19 pandemic on their ACO’s quality scores. NAACOS shared these concerns and a policy recommendation in a recent letter to CMS. The letter explains that while we appreciate numerous CMS policies for ACOs in response to the pandemic, we urge swift action from the agency for 2020 MSSP quality reporting. In the proposed 2021 Medicare Physician Fee Schedule (PFS) Rule, CMS sought comment on an option to provide ACOs the higher of their 2019 or 2020 quality scores for performance year (PY) 2020 due to the impact of the COVID-19 PHE, so long as ACOs fully report on quality measures for 2020. NAACOS and many other stakeholders strongly supported this policy and urged the agency to finalize it.

Unfortunately, CMS decided to maintain its extreme and uncontrollable circumstances policy. Therefore, ACOs will receive the higher of their own 2020 quality score or the mean 2020 MSSP ACO quality score if they are unable to report quality data due to the COVID-19 PHE. We are hopeful that this letter asking the agency to change the policy to provide the higher of the 2019 or 2020 quality scores will result in more shared savings for ACOs. It is critical that CMS take appropriate steps to ensure this once-in-a-century pandemic does not derail the Alternative Payment Model (APM) and value movement.

2020 ACO QUALITY REPORTING CONTINUES
ACO quality reporting for PY20 is currently underway; the deadline to submit quality data is March 31, 2021. CMS is hosting 2020 Web Interface reporting biweekly support calls. The first call took place on January 27, and all calls will be held on Wednesdays from 1:00–2:30 pm ET. These calls will highlight important updates on reporting quality data and offer ACOs a chance to ask questions from CMS subject matter experts. The next call will take place on February 24 from 1:00–2:30 pm ET.

As ACOs continue to report 2020 quality data, NAACOS has also developed a new resource to assist ACOs in understanding policy changes for 2021 and 2022 quality assessments. This resource highlights the key quality assessment and reporting issues ACOs must consider after completing 2020 data submission and turning attention to PY21. Access this member resource today.

BCDA DATA NOW AT PARITY WITH CCLFS
The Application Programming Interface (API) that feeds MSSP ACOs data on a weekly, rather than monthly, basis is now fully on par with the data provided in Claim and Claim Line Feed (CCLF) files. The Beneficiary Claims Data Application Programming Interface (BCDA) is an option for claims data access that ACOs can explore given its more timely delivery of claims, but it had been lacking data available in CCLFs. That’s no longer the case after the recent addition of about 15 fields that were missing. More background on the advantages of the BCDA is available in a NAACOS on-demand webinar. ACOs can sign up for access on the CMS website.

REGISTRATION STILL OPEN FOR NAACOS DIRECT CONTRACTING LEARNING DISCUSSION
Join NAACOS, Direct Contracting Entities, and ACOs considering Direct Contracting participation to share your feedback, questions, concerns, or points of interest. Melissa Schmutzer of Collaborative Health Systems and Andrea Osborne of VillageMD will help facilitate discussion, and we encourage you to send questions or requested conversation topics in advance to directcontracting@naacos.com by February 16, so we can make the most of this opportunity. The goal is to provide a forum for shared learning. NAACOS is planning on hosting these forums on a monthly basis through the spring as we anticipate members will be weighing their participation options for 2022. Register Now!



TAKE ADVANTAGE OF RECENT NAACOS RESOURCES
NAACOS has a number of recently developed resources to help ACOs understand critical policy and program changes. As a member of NAACOS you have free access to all member resources — take advantage of these tools today! Recently released resources include: PRIMARY CARE FIRST MODEL COHORT 2 ELIGIBILITY CHANGES
CMS recently announced a number of eligibility changes for the second cohort of the Primary Care First (PCF) Model. The Request for Applications (RFA) for Cohort 2, scheduled to begin in January 2022, will be open to all primary care practices in the existing 26 PCF regions, regardless of their prior participation in the Comprehensive Primary Care Plus (CPC+) Model. The PCF Model’s second cohort was previously to be reserved for CPC+ participants. The PCF Model aims to test whether incentivizing primary care will reduce hospital utilization and total costs of care by offering performance-based payments. The CMS Center for Medicare and Medicaid Innovation Center (Innovation Center) plans to publish more information about the RFA for Cohort 2 in the Spring of 2021. Learn more about the PCF Model on the Innovation Center website.

NEW CMS ISSUE BRIEF ON CARE MANAGEMENT SERVICES
CMS recently released a new resource, Issue Brief on ACO Approaches to Transitional Care Management and Chronic Care Management. This resource provides examples of ACO approaches to implementing Transitional Care Management (TCM) services as well as Chronic Care Management (CCM) services. This includes best practices and lessons learned about these Medicare services, focusing on topics including staffing structures, provider engagement, beneficiary identification, and progress measurement. ACOs often incorporate TCM and CCM into their broader care management strategies, making this resource a valuable tool.

NAACOS ALL-PAYER COMBINATION OPTION WEBINAR AVAILABLE ON-DEMAND
Speakers from CMS recently presented a webinar for NAACOS reviewing the Quality Payment Program’s (QPP’s) All-Payer Combination Option. That webinar is now available on-demand. ACOs participating in Advanced APMs are increasingly pursuing similar contracts with payers outside of traditional Medicare, and, as a result, there is growing interest in the All-Payer Combination Option. That option allows ACOs to earn Advanced APM bonuses based on their participation in Advanced APMs with payers outside of traditional Medicare, along with their Medicare APM participation. Webinar speakers explained the benefits of this option, how the program works, and how ACOs can earn Qualifying APM Participant (QP) status through their All-Payer Combination Option participation.