COVID-19 and ACOs

NAACOS continues to work with both Congress and CMS to support ACOs’ important work during the COVID-19 pandemic and ensure their future success. NAACOS and nine other leading provider organizations asked Congress and the Trump administration last spring to act quickly to ensure clinicians focused on value-based care are not inappropriately penalized for the extreme costs of handling the COVID-19 pandemic and can continue to focus their energy on patient care. Click on the graphic to the right for more information on how ACOs are leveraging high tech, high-touch population health tools to support patients at high risk for COVID-19.

See Results from Weekly Poll conducted from April 27 through September 14, 2020 about COVID’s impact on in-person visits.

NAACOS Advocacy

  • NAACOS and 11 other organizations ask CMS to provide ACOs with the options to select pre-pandemic years for benchmarks in 2022
  • NAACOS and other leading organizations send letter requesting Congress support value-based payment through COVID stimulus
  • NAACOS letter supports Next Gen extension and asks for further program modifications to protect ACOs in response to COVID-19
  • NAACOS provides detailed comments in response to CMS rules with COVID-19 policies affecting ACOs
  • NAACOS urges swift action to extend the Next Generation ACO Model and announce plans for the future of the Direct Contracting Model
  • NAACOS and eight other leading healthcare associations send comment letter to CMS requesting additional ACO protections in response to COVID-19
  • NAACOS and seven others urge CMS to count diagnoses obtained from audio-only telehealth services for risk adjustment purposes
  • NAACOS asks FCC to expand eligibility of the COVID-19 Telehealth Program
  • Senators support NAACOS position on COVID-19 relief
  • NAACOS and others ask Congress for assistance for providers serving Medicare Advantage beneficiaries
  • NAACOS and others ask CMS to accelerate CPC+ payments in response to COVID-19
  • NAACOS and nine others ask House and Senate leaders for relief from COVID-19 response
  • NAACOS and nine others ask CMS for relief from COVID-19 response
  • NAACOS and 13 others write Congress to address telehealth during the COVID-19 public health emergency

NAACOS Resources


On March 27, President Trump signed the Coronavirus Aid, Relief and Economic Security (CARES) Act, into law. The stimulus package includes over $2 trillion in spending and tax relief to assist the American public and healthcare providers responding to the COVID-19 pandemic. The CARES Act allows for additional care coordination by modernizing regulations (42 CFR Part 2) to make it easier to share the medical records of people with substance use disorders, a change long – called for by NAACOS. The bill provides a further expansion of telehealth services, policies NAACOS has advocated for on Capitol Hill. The legislation also provides $100 billion in grants for hospitals and health providers, temporarily suspends Medicare’s 2 percent sequestration cuts, and increases Medicare payments for COVID-19 patient care.

A section-by-section summary of the CARES Act is available, a summary of the appropriations funding is available.

Additional Congressional Relief

On April 24, President Trump signed into law a $484 billion relief package named the Paycheck Protection Program and Health Care Enhancement Act. This includes more than $300 billion in additional funding for the small business Paycheck Protection Program (PPP), which had previously run out. This package provides an additional $75 billion for providers under the Public Health and Social Services Emergency Fund to support COVID-19 related expenses and lost revenue due to coronavirus. It also allocates $25 billion more for COVID-19 testing, $6 billion for the HHS Inspector General, and other money for the NIH, CDC, and BARDA. Read a summary of the full bill.  

On December 21, Congress passed an omnibus spending and COVID-19 relief bill, which was later signed into law. The package provides $3 billion in new resources for the Provider Relief Fund, expands the Paycheck Protection Program that was established earlier in 2020, providing more money and more flexibility for recipients, and addresses public health in other ways such as providing more money to federal agencies. Additional information can be found in this NAACOS summary.

What other resources exist for ACOs?

Telehealth Resources

Funding Opportunities

  • Updated CMS Fact Sheet on Expansion of the Accelerated and Advance Payments Program for Providers and Suppliers During COVID-19 Emergency (updated October 8, 2020)
  • Paycheck Protection Program (PPP) provided forgivable loans to qualifying small businesses under 500 employees of up to $10 million. The PPP ended on May 31, 2021. Existing borrowers may be eligible for PPP loan forgiveness. SBA also offers additional COVID-19 relief.

Other Resources

  • CMS page with all PHE-related background and guidance
  • COVID-19 Frequently Asked Questions (FAQs) on Medicare Fee-for-Service (FFS) Billing
  • COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers
  • CMS COVID-19 Partner Toolkit
  • CMS guidance on how the COVID-19 PHE is changing shared savings and losses and assignment
  • Medicare Shared Savings Program: CMS Flexibilities to Fight COVID-19
  • CMS publishes fourth interim final rule providing public health emergency flexibilities
  • Administration guidance to health systems and patients as COVID-19 cases decline on providing in-person care
  • CMS Innovation Center announces model changes because of COVID-19
  • CMS Updates Guidance Providing Flexibility on Delaying Non Essential Procedures
  • CMS Issues New Guidance to Nursing Homes on COVID-19 Reporting
  • Non-Emergent, Elective Medical Services and Treatment Recommendations
  • CMS Memo on Exceptions and Extensions for MIPS and Quality Reporting Requirements
  • CMS COVID-19 Emergency Declaration Health Care Providers Fact Sheet
  • CMS Coverage and Payment Related to COVID-19 Fact Sheet
  • CMS Announces Relief for Clinicians, Providers, Hospitals and Facilities Participating in Quality Reporting Programs in Response to COVID-19
  • SAMHSA COVID-19 Public Health Emergency Response and 42 CFR Part 2 Guidance
  • Centers for Disease Control and Prevention (CDC)
  • World Health Organization (WHO)
  • The Institute for Health Metrics and Evaluation (IHME) COVID-19 Projections

Who can I contact to share more information on how COVID-19 is affecting my ACO?

To share more information regarding how COVID-19 is affecting your ACO, please email us at [email protected].

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