NAACOS Newsletter for Members and Partners July 13 2023

Table of Contents

NAACOS ADVOCACY

Ask Your Representatives to Sign Medicare Payment Reform Letter
Join Us for the July ACO REACH Learning Discussion

CONGRESSIONAL UPDATES

Lawmakers Return to Washington

ADMINISTRATION UPDATES

CMS Begins Paying Advanced APM Incentives
Check Your 2022 QPP Preview Reports
MSSP Application Cycle Phase 1 RFI-1 Open
CMS’S Proposed 340B Repayments Have Minimal Impact on ACOs
CMMI to Terminate EMS Model Two Years Early
CMS Releases More Drug Pricing Guidance
FDA Approves Costly New Alzheimer’s Drug
CMS Releases Proposed Home Health Rule
CMMI Reviews Health Equity Aspects of Models
Nominations for Quality Review Committees Now Open
August Webinar on Transitioning to eCQMs and MIPS CQMs

EDUCATION OPPORTNUITIES

Jon Blum to Open Fall Conference
NAACOS in Review: Learn About Hot Topics from ACO Peers
Questions about the QCDR Quality Reporting Process
Discovery Call for Innovaccer Users Planned for August 9
Virtual Affinity Groups Meet This Summer

WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE




NAACOS ADVOCACY


ASK YOUR REPRESENTATIVES TO SIGN MEDICARE PAYMENT REFORM LETTER
Reps. Ami Bera (D-CA) and Larry Bucshon (R-IN) are leading a bipartisan letter to House leaders asking them to support Medicare payment system reforms. The letter discusses how Alternative Payment Model (APM) incentives are set to expire, along with the need to address underlying physician payment issues. This letter comes on the heels of a June hearing held by the House Energy and Commerce Committee where NAACOS testified calling on lawmakers to extend incentives for practices in APMs. The deadline for lawmakers to sign the letter is July 27. Please contact Robert Daley for more information on how to engage your Members of Congress.

JOIN US FOR THE JULY ACO REACH LEARNING DISCUSSION
NAACOS’ next ACO REACH Learning Discussion will take place July 21, 12:00–1:00 pm ET. This month, the topic will focus on capitation management. Participation is limited to those participating in ACO REACH, and advanced registration is required. If you have questions or additional topics you want discussed, please share them in advance by emailing [email protected].

CONGRESSIONAL UPDATES

LAWMAKERS RETURN TO WASHINGTON
The House and Senate reconvened this week following a two-week district work period. The July agenda will feature discussions about annual spending legislation, the Pandemic and All-Hazards Preparedness Act (PAHPA), and reforms to Pharmacy Benefits Managers (PBMs) and price transparency. The House Education and Workforce Committee recently introduced bipartisan legislation to increase price transparency and reduce consolidation. The health package will complement work being done by other committees in the House and Senate.

ADMINISTRATION UPDATES

CMS BEGINS PAYING ADVANCED APM INCENTIVES
CMS recently began distributing advanced APM incentives for Performance Year (PY) 2021. The incentive payment is equal to 5 percent of the estimated aggregate payment amounts for Medicare Part B covered professional services furnished by the Qualified APM Participant (QP) during the “base period,” which is the calendar year preceding the payment year, across all billing TINs associated with the QP’s National Provider Identifier (NPI). As a reminder, these payments are made to the Medicare billing organization (TIN) associated with the clinician attaining QP status, not the ACO or APM entity. Learning resources and fact sheets from CMS are available.
  • Unpaid QPs. CMS published a list of QPs to whom payments have not been completed for various reasons. Clinicians on the list have until September 1, 2023, to complete the 2023 Billing Information Collection Form and submit it to the Quality Payment Program (QPP) Help Desk at: [email protected].
  • First Snapshot for 2023. On July 11, CMS updated its Quality Payment Program Participation Status Tool based on the first snapshot of APM data. The first snapshot includes data from Medicare Part B claims with dates of service between January 1 and March 31, 2023.
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CHECK YOUR 2022 QPP PREVIEW REPORTS
CMS has provided final PY 2022 Merit-based Incentive Payment System (MIPS) scores, available on the QPP portal. During the MIPS Final Score Preview Period, clinicians and ACOs can review final scores in advance of the corresponding 2024 payment adjustments. You should contact the QPP Service Center with any errors or issues at [email protected]. Please also let us know at [email protected] as we would like to quickly identify any system-wide issues. Final scores and payment adjustment information will be released in August 2023. Following final adjustment information being shared in August, there will be a 60-day targeted review period during which you can contest your score. CMS also posted the 2021 QPP Experience Report.

MSSP APPLICATION CYCLE PHASE 1 RFI-1 OPEN
On July 11, the Phase 1 RFI-1 opened for ACOs applying to participate in the Medicare Shared Savings Program (MSSP) beginning January 1, 2024. This phase of the application cycle will be open until August 1, 2023, at 12:00 pm ET. This will be the final opportunity for ACOs to elect to apply for a SKilled Nursing Facility (SNF) 3-day rule waiver, and the final opportunity to add ACO participants and/or SNF affiliate TINs. Current ACOs making modifications to their ACO participant list through the annual change request cycle must also submit any TIN additions by the August 1 deadline. More information on the application cycle and key deadlines is available.

CMS’S PROPOSED 340B REPAYMENTS HAVE MINIMAL IMPACT ON ACOS
CMS published a proposed rule last week that would repay $9 billion to more than 1,600 hospitals that participate in the 340B drug discount program, following the Supreme Court’s decision that cuts to the program were unlawful. CMS proposed a one-time, lump sum payment. The proposed policy presents a positive outcome for some ACOs. The one-time, lump sum payment would not be counted as ACO expenditures, and the reduced conversion factor to maintain budget neutrality requirements could lead to higher shared savings in 2025 and beyond. CMS has released a fact sheet discussing the rule, which is found in the Federal Register. The comment period on this proposed rule ends on September 5. NAACOS explains more in this one-pager.

CMMI TO TERMINATE EMS MODEL TWO YEARS EARLY
The Center for Medicare and Medicaid Innovation (CMMI) announced it will end the Emergency Triage, Treat, and Transport (ET3) model at the end of this year, two years early. The voluntary model of ambulance service providers would pay ambulance service providers for transporting patients to locations other than emergency departments or to treat in place with a qualified partner. It could be a way for ACOs to stave off costly emergency department trips. CMS said the decision was based on low participation.

CMS RELEASES MORE DRUG PRICING GUIDANCE
CMS has revised guidance on its upcoming Medicare Drug Price Negotiation Program, which starts later this year. The program could be a way for ACOs to see more favorable drug prices. The guidance creates more transparency in the negotiation process. The first 10 drugs subject to negotiations will be announced later this summer. Part B drugs will be subject to negotiations taking effect in 2028. Guidance is available.

FDA APPROVES COSTLY NEW ALZHEIMER’S DRUG
The Food and Drug Administration granted full approval of a new drug, Leqembi, to treat adults with Alzheimer’s Disease. The drug is expected to cost $26,500 a year. According to the Kaiser Family Foundation if 5 percent of the 6.7 million Alzheimer’s patients take the drug, it will cost Medicare more than $9 billion a year, which is twice as much as the current most expensive Part B drug, Keytruda. CMS has already set up a registry, which patients must participate in for Medicare to cover the drug.

Compliance Manual

CMS RELEASES PROPOSED HOME HEALTH RULE
On June 29, CMS released the Calendar Year (CY) 2024 Home Health Prospective Payment System Rate Update proposed rule. CMS estimates that Medicare payments to home health agencies in CY 2024 would decrease in the aggregate by 2.2 percent, or $375 million compared to CY 2023. The proposed rule also includes regulations to implement coverage and payments for home intravenous immunoglobulin (IVIG) and Lymphedema compression treatments. The CMS fact sheet and proposed rule are available. Comments are due by August 29.

CMMI REVIEWS HEALTH EQUITY ASPECTS OF MODELS
As part of CMMI’s 2021 strategic refresh, the center conducted a review of all model evaluation reports through June 2022 that included analyses related to health equity. This week, CMMI published a white paper with the findings of this review, which will be used to guide future model development. Key findings from the review:
  1. Variable quality of race/ethnicity data in Medicare and Medicaid claims data creates challenges for understanding whether models reach underserved individuals.
  2. Model designs have not always considered specific needs of underserved beneficiaries or prioritized closing gaps in care.
  3. Model designs that do not prioritize enrolling underserved beneficiaries result in small sample sizes that limit the ability to draw conclusions from analyses related to equity.
NOMINATIONS FOR QUALITY REVIEW COMMITTEES NOW OPEN
The Partnership for Quality Measurement (PQM) has replaced the National Quality Forum’s consensus-based endorsement and maintenance process for quality measures used in CMS programs. The new Pre-Rulemaking Measure Review (PRMR) process will be launched this fall. Battelle is now accepting nominations for participation in committees. Specifically, the clinician committee will be responsible for reviewing measures to be used in MSSP. Individuals can nominate themselves or others, and nominations are due July 30. More information regarding membership opportunities is available on the PQM website.

AUGUST WEBINAR TO COVER TRANSITIONING TO ECQMS AND MIPS CQMS
NAACOS will hold a webinar on August 2 at 3:00 pm ET reviewing quality submission approaches for MSSP ACOs. Attendees will hear updates from NAACOS staff on proposed 2024 Medicare Physician Fee Schedule rule provisions affecting quality reporting and feedback from ACOs implementing these changes. Northwestern Medicine will share how its ACO is preparing for the 2025 requirement to move to electronic clinical quality measure (eCQM) or MIPS CQM quality reporting approaches. Register now!

EDUCATION OPPORTUNITIES

JON BLUM TO OPEN FALL CONFERENCE
Join us September 20–22, 2023, at the Marriott Marquis Washington, D.C., for the fall conference! Jon Blum, CMS principal deputy administrator and chief operating officer, will open the fall conference with insights into CMS’s policy for value-based care models and the future direction for federal value-based payment policy. In addition to our plenaries with CMS officials and other value-based care leaders, 16 breakout sessions will deliver actionable knowledge for new ACOs and experienced ACOs in all models. Full agenda is available!

In conjunction with the fall conference, NAACOS is offering three concurrent workshops that take a deep dive into key issues facing ACOs. Pre-conference workshops will be held September 20 from 1:00–5:00 pm ET. These workshops require separate registration from the main meeting.

Virtual and in-person registration options are available and, as always, the entire conference will be recorded. Register early and save! Register before August 4 for the in-person or virtual conference and receive a discount.

Exhibitor and sponsor opportunities are now available and going fast! The conference will feature more than 60 exhibitors with products and services specifically for the accountable care community. Check out the prospectus for new and fun opportunities. Partners, reserve your space today!


NAACOS IN REVIEW: LEARN ABOUT HOT TOPICS FROM ACO PEERS
Are you missing opportunities to interact with other NAACOS members on hot topics? You are if you have not signed up for our NAACOS listservs! If your organization is a NAACOS member, then you are eligible. Visit NAACOS ListServs and choose the ones that best fit your educational needs. The Executive ListServ is for general questions for any type of ACO while the ACO REACH Listserv is specific to ACO REACH. In addition, you can sign up for access to Knowledgebase that will allow you to search previous discussions.

QUESTIONS ABOUT THE QCDR QUALITY REPORTING PROCESS
Join the upcoming discovery call on Qualified Clinical Data Registry (QCDR) reporting on July 24 from 4:00 pm to 5:00 pm ET. During this call you will hear from Wilson Gabbard, vice president, quality and condition management enterprise population health for Advocate Health, and CarolAnn Hudson, clinical director, population health for Lifepoint Health, as they share their experiences. There will be ample time for peer-to-peer discussion after brief presentations. Sign-up to join your ACO colleagues.

DISCOVERY CALL FOR INNOVACCER USERS PLANNED FOR AUGUST 9
At the request of ACO members, NAACOS will hold a discovery call for Innovaccer users on August 9 from 3:00 pm to 4:00 pm ET. This meeting will be hosted by Dr. Tom Kloos, VP Atlantic Health System, and President Atlantic ACO. During the call we will gather information on challenges, compare notes, and share best practices, workflows, etc. If you are a current Innovaccer user, sign-up to join this organizing call for members.

VIRTUAL AFFINITY GROUPS MEET THIS SUMMER
The final three summer virtual affinity groups will meet from 3:00 pm to 4:00 pm on the next three Tuesdays. To attend these invaluable peer-to-peer sessions, sign up with the link below and add to your calendar.

Data and Analytics Affinity Group
July 18 from 3:00 pm to 4:00 pm ET
Register now!

Executive Affinity Group
July 25 from 3:00 pm to 4:00 pm ET
Register now!

CMO and Clinical Affinity Group
August 1 from 3:00 pm to 4:00 pm ET
Register now!

WHAT WE’RE WATCHING: NEWS ABOUT ACOS AND HEALTH CARE
  • Senator Sheldon Whitehouse (D-RI), the Chairman of the Senate Budget Committee, recently requested the Congressional Budget Office to examine the effects that reforms to health care delivery systems, including the use of ACOs, have on costs and health outcomes.