  | 
                                            Newsletter
                                                    for Members and Partners | 
                                         
                                        
                                            | August
                                                    25, 2022 | 
                                         
                                    
                                 
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   SUBMIT
                                    COMMENTS IN RESPONSE TO CY23 MPFS PROPOSED RULE   NAACOS has drafted a
                                detailed comment letter in response to the proposed 2023 Medicare
                                Physician Fee Schedule (MPFS) rule. This regulation includes many positive changes to
                                the Medicare Shared Savings Program (MSSP), including the glidepath to risk, changes to
                                financial methodologies, advance shared savings payments for certain ACOs, and an
                                alternative quality performance standard. It is critical that CMS hear directly from
                                ACOs, and we encourage members to use all or portions of our letter in your comment
                                submissions. If you have any questions about our draft letter, please contact [email protected].
                                
                                CATCH
                                    ON-DEMAND WEBINAR: MSSP VS. ACO REACH FINANCIALS   If you missed this
                                week’s NAACOS webinar on understanding your participation options between MSSP and ACO
                                REACH, you can still catch it on-demand. The webinar reviewed the
                                financial methodology and provided an actuarial comparison between MSSP and REACH. This
                                followed the recent release of the financial specifications for the ACO REACH Model. The
                                CMS Innovation Center’s Corey Rosenberg, ACO REACH Model lead, joined as a speaker and
                                answered a few questions as well. If you have follow-up questions or would like more
                                information about ACO REACH, contact NAACOS staff at [email protected].
                                
   NAACOS
                                    LAUNCHES MONTHLY GOVERNMENT RELATIONS ADVOCACY CALLS  Earlier this
                                summer, the NAACOS government affairs team began holding monthly calls for our members’
                                in-house or contracted government relations teams. These calls are an informal forum for
                                sharing updates on congressional outreach and materials that can be used in
                                congressional meetings. The calls are scheduled for 2:00 pm ET on the Third Thursday of
                                each month. The next call is scheduled for Thursday, September 15. Contact Aisha
                                    Pittman or Robert
                                    Daley to have your organization’s in-house or external government relations team
                                join. 
  
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                                                    Welcome
                                                            New Business Partners
                                                 | 
                                             
                                            
                                                Alliant
                                                        Insurance Services  As
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                                                        Health  Videra
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                                                  | 
                                             
                                        
                                     
                                
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                                  DRUG
                                    PRICING BILL SIGNED INTO LAW  On August 16, President Biden signed the
                                Inflation Reduction Act (IRA) into law, which establishes a Medicare drug pricing
                                negotiation program for certain high-priced pharmaceuticals, provides rebates for
                                Medicare Part B or D drugs when prices increase faster than inflation, and lowers
                                out-of-pocket thresholds for certain Medicare Part D drugs. The law also extends
                                Affordable Care Act (ACA) tax subsidies through 2025. 
   With consideration of
                                the IRA now complete, lawmakers will return to Washington in September to begin laying
                                out priorities that need to be addressed before the end of the year. NAACOS will be
                                strongly advocating for Congress to extend the 5 percent Advanced APM bonus. Please
                                support these upcoming activities:
                                
                                    - Sign-on to the national stakeholder, ACO, and physician practice letter that
                                        asks congressional leadership to extend the bonuses. You will receive
                                        information about signing on by the end of the week.
 
                                    - Join a congressional briefing on extending the bonuses on September 29.
                                        Registration will be available next month.
 
                                 
                                    
                                
                                  MSSP
                                    ACOS RECEIVED EMBARGOED 2021 PERFORMANCE RESULTS  CMS has sent MSSP ACOs
                                their embargoed 2021 performance results. As always, the results are embargoed. CMS
                                typically lifts the embargo a few weeks to a month later. The PHE was in effect last
                                year, so CMS waived any shared losses. Additionally, the quality results will be
                                displayed differently this year because of different reporting methods (electronic
                                clinical quality measure [eCQM], Merit-based Performance System clinical quality measure
                                [MIPS CQM] or Web Interface) and different measures sets associated with the reporting
                                mechanisms. Lastly, ACOs were awarded the higher of their own quality score or the mean
                                score.
                                
                                    - Last year was a banner year for MSSP with ACOs generating $4.8 billion
                                        in gross savings and $2.1 billion after accounting for shared savings payments.
                                        NAACOS encourages members to publicize their results. Use our media kit to
                                        help tout your savings once the embargo is lifted.
 
                                    - NAACOS has heard from ACOs whose final settlements varied drastically from
                                        projections because of a combination of the rural glitch, a cap on risk score
                                        growth, and the lack of a cap on regional risk scores. These policies overall
                                        caused ACOs’ final benchmarks to drop significantly. If you have seen similar
                                        issues, please let us know at [email protected].
                                    
 
                                 
                                CMS
                                    RELEASES NAMES OF PROVISIONALLY ACCEPTED REACH ACOS   Last week the CMS
                                Innovation Center posted the names of the 110 provisionally accepted applicants
                                for the ACO REACH Model as well as those participating in the third Implementation
                                Period, which started earlier this month. The Innovation Center also published an
                                updated version of its application fact sheet and FAQs. We congratulate all who were accepted. It is unusual for
                                the Innovation Center to post the names of anyone other than who is participating in its
                                models, but the agency and model are under great political pressure and are erring on
                                the side of transparency. The Innovation Center did not publish the names of those who
                                applied and weren’t accepted. NAACOS continues to follow the negative rhetoric the model
                                is receiving and counter it when appropriate. 
  
                                     CMS
                                    TELLS PROVIDERS TO “PREPARE” FOR THE END OF THE COVID-19 PHE  In a recent blog post, CMS outlined a high-level “roadmap” for the
                                end of the COVID-19 Public Health Emergency (PHE), telling providers to “prepare for the
                                end of these flexibilities as soon as possible.” The PHE is scheduled to expire on
                                October 13, but NAACOS is expecting it to be extended at that time, either through the
                                end of the year or for another 90 days into January. The administration has promised at
                                least a 60-day notice of the PHE expiring. In the meantime, CMS outlined its thinking
                                about the PHE’s expiration and how it plans to support providers and monitor data on
                                certain PHE-era flexibilities. While Congress granted a 151-day extension of telehealth
                                flexibilities, CMS is encouraging providers to “to prepare to return to normal
                                operations.” A series
                                    of fact sheets notes what is set to lapse at the end of the PHE, including those within MSSP around the waiving of shared losses,
                                quality reporting, and removing of COVID-19 expenditures from financial calculations.
                                Please refer to the NAACOS
                                    COVID-19 page for more information. 
   REMINDER:
                                    CMS IS REQUESTING BILLING INFORMATION FOR CERTAIN QPS  On August 10, CMS
                                issued an advisory in the Federal Register to alert certain
                                clinicians who are Qualifying APM participants (QPs) and eligible to receive an Advanced
                                APM Incentive Payment that CMS does not have the current billing information needed to
                                disburse the payment. The list of QPs with unverified billing information, along with
                                instructions on how to update billing information is available online. QPs that have not
                                received payments must update their information no later than Tuesday, November 1.
                                
   CMS
                                    POSTS FINAL 2021 MIPS SCORES  CMS recently posted final MIPS scores for
                                Performance Year 2021, which dictate 2023 payment amounts. For ACOs subject to MIPS,
                                those with the Security Official role can access the Quality Payment Program website to
                                view 2021 performance feedback including the final score and resulting payment
                                adjustments. More information is available in this CMS FAQ. 
  
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                                                    Welcome
                                                            New Associate ACO Member  Responsive
                                                        Care Solutions  Sarasota,
                                                        FL
                                                 | 
                                             
                                            
                                                
                                                    Welcome
                                                            New Multi-ACO Member  Vytalize
                                                        Health  Headquarters:
                                                        Hoboken, NJ
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                                  CONFERENCE
                                    REGISTRATION STILL OPEN – IN PERSON AND VIRTUAL  Join us September 8–9,
                                2022, for the NAACOS Fall Conference at the Marriott Marquis in Washington, D.C. with
                                optional half-day workshops on September 7 for in-person participation only. The agenda
                                will feature leading ACO experts and CMS officials sharing timely and essential
                                information for ACOs. 
   Check out the agenda! 
   Two pre-conference workshops
                                on Wednesday, September 7, from 1:00 pm to 5:00 pm can enrich your conference learning.
                                The two workshops will focus on:
                                
                                    - ACO REACH Compliance and Waivers chaired by Beth Patak, Equality Health
 
                                    - Preparing for eCQM Reporting chaired by Anna Taylor, MultiCare Connected Care
                                    
 
                                 
                                Individuals unable to attend the conference in-person can participate in the live
                                webcast of the conference. The live webcast includes all breakout sessions and
                                plenaries, as well as the sponsored breakfasts. Live webcast participants also receive
                                six months of access to the recordings of the sessions so that you don’t miss out on
                                any! 
   Register Now for Live Webcast! 
   As always, it’s
                                never too late to register for in-person at the Marriott Marquis Washington, D.C!
                                Take advantage of our group rates! We are offering group rates for both the in-person
                                and virtual conference. 
   To register at the group rate, please contact Emily Perron.
                                
  
                                   
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