CMS Physician Fee Schedule Proposed Rule Comments

Washington D.C. (Oct, 2020) – On October 5, 2020, the Next Gen ACO Coalition submitted comments in response to the Centers for Medicare & Medicaid Services (CMS) Physician Fee Schedule Proposed Rule. The letter responds to the agency’s proposals, including a proposal to transition Medicare ACOs to a new quality reporting system and performance standards and proposals around the advanced alternative payment model (APM) thresholds to qualify for a five percent incentive payment.

The Coalition calls for CMS to delay implementation of its quality proposals. As ACOs and their communities continue to recover from and respond to COVID-19, sweeping changes to the quality reporting and performance standards would create additional burden. In addition, the Coalition reiterates its call for CMS to freeze the patient count threshold for ACOs in 2021 to ensure that ACOs taking the highest levels of risk available in traditional Medicare qualify for the bonus as intended by Congress.

The full letter is available here.

Members of Congress Urge House Leadership to Stop MACRA APM Threshold Cliff

Washington D.C. (Sept, 2020) – Members of the House of Representatives sent a letter to House Speaker Nancy Pelosi and Minority Leader Kevin McCarthy encouraging the House to take action to ensure that entities participating in value-based care contracts continue to qualify for bonuses intended to reward clinicians that participate in performance-based risk in traditional Medicare.

The Medicare Access and CHIP Reauthorization Act (MACRA) created an incentive payment for entities that take on certain levels of financial risk in traditional Medicare. The statute established certain requirements to qualify for the bonus payments. One such requirement is achieving a threshold related to participation. In 2021, the threshold test jumps dramatically. Now, risk-bearing accountable care organizations (ACOs) and Members of Congress are calling for relief from this cliff. The letter urges House leadership to act to prevent the cliff from going into effect.

The Coalition thanks the Members of Congress for their support in this important effort.

The full letter is available here.

NGACO Model Adjustments for COVID-19

Washington D.C. (June, 2020) – The NGACO Coalition’s Feedback on Model Adjustments for COVID-19 (excerpt)

On behalf of the Next Generation ACO Coalition, we write to thank you for the flexibilities you have implemented, including extending Next Gen for 2021, and request additional modifications to the program to bolster the move to performance-based risk.

Next Gen is currently the most advanced model in the CMS Innovation Center’s performance-based risk portfolio. The model tests higher levels of financial risk, reward, and accountability for patient populations. Since 2016, Next Gen ACOs have been leading the health care system’s transformation from volume to value.

Next Gens have rapidly deployed care coordination and care management services to prevent the spread of COVID-19 and care for patients with chronic conditions who are under stay-home orders. Examples include…

The full feedback document is available here.

CMS Extends Next Gen ACO Model for 2021

Washington D.C. (June, 2020) – Today, the Centers for Medicare and Medicaid Services (CMS) Innovation Center announced that the Next Generation ACO model will be extended for an additional year. On behalf of our 21 ACO members and the thousands of patients we serve across the country, the Next Generation ACO Coalition thanks CMS and the Innovation Center team for recognizing the value of this model and strengthening the future of accountable care. This extension ensures that we can continue providing quality, affordable services to our communities.

Next Gen is the most advanced model in the CMS Innovation Center’s performance-based risk portfolio. The model tests higher levels of financial risk, reward, and accountability for patient populations. Since 2016, Next Gen ACOs have been leading the health care system’s transformation from volume to value, a movement that can now continue through 2021.

An extension of the model does not mean that our work is done. In the short term, we will continue to deploy care coordination and care management services to prevent the spread of COVID-19 and care for patients with chronic conditions who are under stay-home orders. As the pandemic recedes and states return to full operations, we remain committed to managing population health and accelerating the movement to performance-based risk. We thank CMS for partnering with us to advance these goals.

Please see the CMS flexibilities blog post and model flexibilities table for additional information on the extension.

NGACO Coalition Asks CMS to Freeze MACRA Patient Count Threshold in Response to COVID-19 Outbreak

Washington D.C. (April, 2020) – The NGACO Coalition, which represents 20 of the Next Generation ACOs, is requesting that the Centers for Medicare and Medicaid Services use its regulatory authority to freeze the MACRA patient count threshold for Advanced APM bonus eligibility at current levels. The attached document outlines the challenges presented by planned threshold increases, especially during a time when Next Generation ACOs are marshaling all possible resources to combat COVID-19.

The full letter is available here.

NGACO Coalition Feedback on Direct Contracting Model

WASHINGTON, D.C. (Jan, 2020) – The NGACO Coalition’s Feedback on Direct Contracting Model (excerpt)

CMMI Should Reduce the Financial Exposure in the Direct Contracting (DC) Model

Issue: The current financial model includes a 2-5% discount for global model participants; a 2% retention withhold for early termination; a 5% quality withhold; and a leakage withhold. CMMI limits the maximum upward and downward adjustment that can result from incorporating regional expenditures into the benchmark, with an upward limit of 5% and a downward limit of 2%. CMMI has not yet released the risk adjustment methodology for DC. The total impact of these withholds and discounts represents significant risk exposure for participants.

NGACO Coalition Recommendations:

  • CMMI should reduce or waive some of the model’s withholds and discounts:
    • CMMI should waive the 2% retention withhold for entities with experience with two-sided risk as they have made significant investments in the infrastructure to manage risk and have demonstrated their commitment to do so.
    • CMMI should reduce the discount percentage in the global model.
    • CMMI should increase the cap on the regional component of the benchmark from 5% to 10% to align with Next Gen. The floor should remain at 2%.
  • CMMI should ensure that the DC risk adjustment methodology aligns to the risk adjustment methodology for Medicare Advantage (MA) (i.e., uncapped).
  • In the global model total care capitation track, DCEs should be able to negotiate their capitation with CMS, including the option for a seasonality adjustment to reflect on-the-ground factors specific to the DCE’s patient population. DCEs should have the option for a higher upfront payment and reconciliation, similar to the approach offered for primary care capitation.
  • CMMI should allow Standard DCEs to nest High Needs DCEs. Removing the most complex subset of the population and those providers creates substantial financial risk and results in an unfair playing field for Standard DCEs as compared to High Needs DCEs.

The full feedback document, including other issues and recommendations, is available here.