NAACOS RECOMMENDATIONS FOR MSSP CHANGES FOR 2025
NAACOS will now be focused on advocating for changes that we would like to see CMS incorporate in next year’s rulemaking. NAACOS will be advocating for Enhanced Plus, prospective population-based primary care payment, ensuring Medicare clinical quality measures (CQMs) remain as reporting option for several years, improving benchmarks and driving more innovation in the program. Please review the NAACOS draft letter to CMS on priorities for MSSP and send any suggestions to [email protected].
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LETTER TO CMS ADDRESSES SAFETY-NET BARRIERS TO APM PARTICIPATION
This week, NAACOS wrote CMS leadership suggesting numerous ways the agency can make APM participation easier for safety-net providers and the rural and underserved communities they serve. NAACOS asked that CMS recognize the fundamental differences in how care is provided and paid for and consider developing new ACO tracks and sets of waivers specifically for rural and underserved communities.
DECEMBER ACO REACH LEARNING DISCUSSION
Join NAACOS for its next ACO REACH Learning Discussion on December 15 at 12:00 pm ET. This month, we’ll spend time revisiting an earlier topic about a potential full-risk model in MSSP that could serve as an off-ramp for REACH or an on-ramp to a future ACO model out of the Innovation Center. We held a similar conversation in September but want to revisit as we prepare to give CMS feedback on a possible “Enhanced Plus” model for next year’s rulemaking cycle. As always, we’ll have time devoted for additional topics you want to discuss. These monthly calls offer a chance to connect with peers about important topics related to the model. If you’re interested and not already signed up, register now!
CALL FOR STORIES OF POTENTIAL FRAUD DETECTION
Recently, NAACOS heard from ACO members who have identified potential issues of fraud in their claims data, particularly around durable medical equipment. NAACOS has been considering policy recommendations for removing fraudulent charges from ACO expenditures. We’re also identifying approaches to notify CMS, the HHS Inspector General, and MACs about potential fraud that ACOs spot.
Please join us for a call on January 22 from 2:00 to 3:00 pm ET to hear more information about this issue. In the meantime, we would like to hear your experiences with finding fraud in your populations, recommendations on solutions for removing it from ACO spending, and challenges you’ve learned along the way. Please reach out to [email protected] to share your thoughts and ideas on this hot topic.
CONGRESS TEES UP HEALTH CARE PRIORITIES
As Congress prepares to recess for the holidays, lawmakers have been busy preparing health care priorities that will likely be addressed in January.
- Health Costs — This week the House voted and passed the Lower Costs, More Transparency Act (H.R. 5378). This comprehensive health care package includes a two-year delay of Medicare disproportionate share hospital cuts, along with reauthorizing the Community Health Centers and Teaching Health Centers Graduate Medical Education Programs. It also imposes new requirements on pharmacy benefit managers and reduces payments to off-campus hospital outpatient departments by approximately $3.7 billion and increases hospital pricing transparency and 340B reporting requirements.
- APM Extension and Doc Fix — The House Energy and Commerce committee approved several health care bills last week including a short-term extension of Medicare’s advanced APM incentives and a partial offset of the 2024 Medicare physician fee schedule cuts that will begin in January. During the markup, Committee Ranking Member Pallone (D-NJ) expressed concern with the reduced size of the advanced APM incentives and encouraged the committee to work together to strengthen the provisions before it’s considered by the entire House. The Senate Finance Committee approved similar bills in November that would extend value-based care incentives and adjust physician payments for 2024.
- NAACOS is pleased that the advanced APM incentives remain a part of the discussions. However, the cost of extending the incentives will continue to be our limiting factor. NAACOS will continue to advocate for the highest possible incentive payment for clinicians in advanced APMs. Please reach out to your members of Congress and ask them to support an extension of the APM incentives. Please contact Robert Daley for assistance with talking points and staff contact information.
- Lawmakers Call on Leaders to Prevent Medicare Cuts — Reps. Miller-Meeks (R-IA), Bera (D-CA), Bucshon (R-IN), and Schrier (D-WA) sent a letter with colleagues to House and Senate leadership urging congressional action to prevent the 3.37 percent cut in Medicare reimbursement to physicians that is scheduled to go into effect at the end of the year.
CMS INNOVATION CENTER CORRECTS WAGE INDEX ISSUE IN ACO REACH
The CMS Innovation Center announced it will update the ACO REACH rate book to better account for upcoming changes to the hospital wage index. This should eliminate any discrepancies that may have occurred because of changes to hospital payments. Some ACOs would have seen much higher payments in the performance year than what was accounted for in their benchmarks. This is a result of NAACOS’ advocacy and your support. While CMS is only updating the geographic factors of the rate book, we are encouraging the agency to do a full update of the rate book to account for any finalized changes across payment systems. Thank you for all your attention to this issue in recent weeks. We are still working to account for additional changes in underlying Medicare payment policy, including 340B drugs.
QUALITY MEASURES UNDER CONSIDERATION LIST POSTED FOR COMMENT
The 2023 Measures Under Consideration (MUC) list is now available for public comment on the Battelle Partnership for Quality Measurement (PQM) website. The list outlines quality measures CMS is considering adding to various Medicare programs in future years, including the Medicare Shared Savings Program (MSSP). CMS outlines two measures for potential inclusion in the MSSP in future program years, Connection to Community Service Provider (MUC2023-199) and Resolution of at least 1 Health Related Social Need (MUC2023-210). CMS will accept public comments on the measure and will also hold a listening session where stakeholders can share their feedback on December 14 at 11am ET. NAACOS holds a seat on the Pre-Rulemaking Measure Review (PRMR) committee responsible for sharing feedback with CMS on these measures. If you have feedback to share with NAACOS, please email [email protected].
CMS CLARIFIES PREV-7 QUALITY MEASURE CALCULATION
The ACO Spotlight newsletter recently highlighted a quality measure change for PY 2023, when the CMS Web Interface quality measure PREV-7 (influenza immunization) was updated to capture two flu seasons during the measurement period (flu season 2022-2023 and flu season 2023-2024). For this measure, a patient is counted only once in the denominator and once in the numerator whether the patient has a qualifying encounter for a single flu season or both flu seasons. A provider must have documentation showing the patient received immunization for the flu season(s) for which the patient was sampled to meet performance for this patient. Patient sample files will contain the same set of variables included in prior years, with the addition of two new indicators that correspond to the two separate flu seasons. The indicator(s) will be checked if the beneficiary qualifies for the sample based on that timeframe. Performance is scored differently for the measure when reported via MIPS CQM, when the measure is either met, not met or a denominator exception applies for each qualifying encounter (scored at the encounter level). In this case the patient can be counted twice in the denominator and twice in the numerator. For PY 2023, the measure will have a flat benchmark for those reporting via Web Interface. Specification information is available on the CMS website. CMS directs ACOs to contact the Quality Payment Program (QPP) Help Desk with any questions.
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SSM Health
St. Louis MO |
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DETAILED AGENDA NOW AVAILABLE FOR 2024 BOOT CAMPS!
Join us February 8–9 at the Marriott Orlando Airport Lakeside for our 2024 Boot Camps. We will be featuring two concurrent boot camps that teach ACOs how to succeed in key functional areas. One will focus on data and analytics, sponsored by Wakely and Diagnostic Robotics, and a second on best practices for clinical operations, sponsored by Brilliant Care and iRhythm. Participants must register for one boot camp and may attend only that one. Daily lunches and a reception will be held jointly so that attendees at both boot camps may benefit from increased networking opportunities. This boot camp is only offered for in-person participation. There is no virtual option. Boot camps are not open to business partners. Space is limited to 100 people per boot camp.
Registration Rates:
ACO Member – $1,195 per person
ACO Non-Member – $1,495 per person
ACO Member Group Rate – $5,000 for up to 5 individuals **Mix and match your group rate! Those registered under a group rate do not all need to be going to the same boot camp.**
Register NOW!
REGISTER NOW FOR SPRING 2024 CONFERENCE
Meet us at the Baltimore Hilton Inner Harbor on April 10–12 for the Spring 2024 Conference! The agenda will feature leading health care experts and CMS officials sharing timely and essential information for ACOs. Registration is now open for both in-person and virtual participation. Member ACOs get an additional discount when they register groups of individuals. More information can be found on our website. Register early and save! Sponsor and exhibit opportunities for the Spring 2024 Conference are now available! Reserve your space today!
ENGAGING PROVIDERS IN ANNUAL WELLNESS VISITS
The NAACOS December Learning Lab will focus on engaging providers in annual wellness visits (AWVs), as well as looking at how additional staff can complete AWVs for your organization. During this month’s 90-minute event on December 21 from 2:00 pm to 3:00 pm ET Brandy Smuzeski, Medical Advantage TDC GROUP, will review their process for engaging physicians and staff in AWVs. You will then hear from Dr. Harmeetinder Bassi, Summit Health/Village MD, who will provide their process of provider engagement including EHR updates to improve process for providers as well providing a quality improvement perspective. If you have already signed up for the AWV learning lab, we look forward to you joining the session. If you are an ACO member who has interest in the AWV process, join the Learning Lab series!
ACOS INVITED TO LEARN ABOUT BUILDING PARTNERSHIPS TO SUPPORT HRSN
The HHS Administration for Community Living (ACL) is inviting hospitals, health systems, ACOs, and community-based organizations (CBOs) to a special series of learning events around collaborative approaches to screening for health–related social needs (HRSN), connecting with community-based social services, and supporting transitions pre- and post-discharge. The monthly meeting series and peer discussion groups will run from January through August 2024. The goal is to leverage community partnerships and assets to address patient’s unmet health-related social needs. ACOs are invited to participate with hospital and CBO partners as the series will address team-based approaches to care management and community health integration post-discharge. If your organization is interested in participating, please complete this brief survey prior to January 12, 2024, to indicate interest: ACL Care Transitions ECHO (smartsheet.com). If you have any questions, please contact [email protected]. More information about the curriculum is available.
MEDICARE ACO DRUG SPENDING FOR AGE-RELATED MACULAR DEGENERATION
Did you know that for ten percent of MSSP ACOs 2-to-4 percent of the total spending was for Part B drugs to treat age-related macular degeneration (AMD) in 2021? In the past five years, ACO expenditures for this progressive eye disease have surged by 29 percent due to increased utilization of Eylea ($1,641 per treatment) and decreased use of Avastin, a comparable, lower-cost alternative ($62 per treatment). Given the high variation in drug utilization by state, market, and organization, ACOs have opportunities to manage spending while maintaining quality of care. Read more about the variation in Part B drug spending for AMD and implications for ACOs in a new Institute for Accountable Care (IAC) white paper. Contact IAC at [email protected] to learn more about Part B drug spending in your market.
| WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE |
- The Medicare Payment Advisory Commission (MedPAC) met last week to discuss draft payment recommendations for 2025. The commissioners will vote on these recommendations during the next meeting on January 11 and 12.
- Physician Payment — Provide physicians with a payment update equal to half the Medicare Economic Index and establish an add-on payment (15 percent for primary care and 5 percent for non-primary care) for services furnished to low-income Medicare patients.
- Hospital Inpatient & Outpatient — Update hospital payments by 1.5 percent above current law and redistribute existing Medicare safety-net payments via the Medicare Safety- Net Index developed by the commission.
- Other Fee Schedules — MedPAC will also recommend that Congress reduce 2025 payment rates for home health agencies by 7 percent, skilled nursing facilities by 3 percent, and inpatient rehabilitation facilities by 5 percent.
- On December 8, CMS uupdated its Quality Payment Program Participation Status Tool based on the third snapshot of APM data. The third snapshot includes data from Medicare Part B claims with dates of service between January 1 and August 31, 2023.
- Senate Budget Committee Chairman Sheldon Whitehouse (D-RI) and Ranking Republican Chuck Grassley (R-IA) opened a bipartisan investigation into the effects of private equity ownership on hospitals, the same day the White House unveiled a new set of policies aimed at unpacking private equity’s impact on health care overall.
- The White House recently published The U.S. Playbook to Address Social Determinants of Health, which highlights federal agencies’ actions to address SDOH and outlines a framework for agencies and organizations to incorporate SDOH considerations in future policies.
- The Berkeley Research Group published a roadmap for transitioning to value-based care, particularly for all payers.
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