Welcome to the Accountable for Health (A4H) newsletter, including legislative and Administration updates, accountable care news, and resources.

A4H Activity

A roundup of our recent activity in Washington, DC:

  • Met with several House offices, including Representatives Amo (D-RI), Chu (D-CA), Horsford (D-NV), Mullin (D-CA), Ross (D-NC), Murphy (R-NC), Kustoff (R-TN) and Boyle (D-PA), to discuss the importance of accountable care, conveying the need for greater certainty around full risk and global risk accountable care models, and discussing end of year priorities around Medicare physician payment.
  • Engaged with Democratic Whip Catherine Clark (D-MA) to discuss accelerating the transition from fee-for-service to accountable care. A4H also raised the need for Congress to address Advanced Alternative Payment Model (APM) bonuses before the end of this year.
  • Convened our Specialty Care Committee to discuss provisions and requests for information related to specialty care providers in the Medicare Physician Fee Schedule proposed rule.
  • Met with CMS and Innovation Center staff to discuss recent developments in full and global risk models and the Medicare Physician Fee Schedule proposals related to accountable care.

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Congressional News

Both the House and Senate are in recess until September 9th.

A4H Provides Input on 21st Century Cures Initiative. Earlier this summer, Representatives Diana DeGette (D-CO) and Larry Bucshon (R-IN) released a request for information (RFI) seeking stakeholder feedback on the 21st Century Cures Act (Cures Act) and the draft version of Cures 2.0. The Cures Act was intended to advance medical research and health care delivery, including provisions impacting biomedical research funding and innovation, mental health care reform, drug development, and health information technology. Lawmakers are now seeking feedback on future legislation in these areas. A4H’s response focused on the importance of population health data and secure health information exchange for effective accountable care. In addition, A4H joined 37 other organizations in a letter urging lawmakers to address gaps and challenges in data sharing and our health data infrastructure. A4H expects additional work on these priorities through the end of the year and into 2025.

Administration

CMS Finalizes Transforming Episode Accountability Model (TEAM). The five-year mandatory model is intended to provide Medicare beneficiaries with coordinated, high-quality care during and after certain surgical procedures. TEAM will begin in 2026 and will have graduated risk through different participation tracks. A4H submitted comments on TEAM and is pleased that CMS adopted some of our recommendations, including lengthening the period safety net hospitals can stay in upside-only tracks, reducing the model discount, and revisiting the low-revenue threshold. A fact sheet on TEAM can be found here, and the model webpage can be found here.

A4H Submits Comments on Proposed Rule to Mitigate the Impact of SAHS Billing Activity on Medicare Shared Savings Program ACOs. A4H submitted comments supporting the agency’s proposal to remove payments for certain catheter codes from expenditures and revenue calculations for CY 2023 and encourages continued attention to identifying and mitigating the impacts of ongoing and future fraud, waste and abuse schemes. In the letter, A4H highlighted how accountable care organizations (ACOs), because of their focus on data and population health information, are uniquely well-situated to identify early aberrant billing patterns, unusual utilization and spending trends. A4H encouraged CMS to finalize the rule as quickly as possible to minimize the delay of shared savings. We are also pleased to see the agency taking additional steps through the Medicare Physician Fee Schedule Proposed Rule and A4H will be submitting comments on that proposal as well.

CMS Announces Changes to ACO REACH Model. According to CMS, the changes to the Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) Model come in response to findings from the PY 2022 Global and Professional Direct Contracting Model Evaluation Report and “feedback from interested parties.” The model updates include benchmark adjustments, continued implementation of the V28 risk adjustment model, and a stop-loss adjustment. The changes will begin in performance year 2025 (PY 2025). A webpage with full details on the model’s updates can be found here. A4H is collecting feedback from our members about these changes and continuing to engage with the CMS Innovation Center about model design and improvements for the future.

Resources

Health Affairs Forefront Article on Provider-Led ACOs. The most recent article in the Health Affairs Forefront series on Accountable Care for Population Health, Closing The Gap In Value-Based Care: Lessons From Provider-Led ACO Experience, analyzes barriers to widespread value-based care (VBC) adoption from the perspective of an ACO participating in the Direct Contracting and ACO REACH Models. The authors recommend adopting four pillars to address these barriers: full risk-sharing options for ACOs, upfront capitated payments, financial predictability, and sustainable payment formulas, noting that such changes would incentivize participation in primary care-centered models and would strengthen the Medicare Shared Savings Program (MSSP). The authors also suggested extending the duration of ACO REACH.

Upcoming Events

Double Click on Accountable Care. We have a great line-up of speakers on September 10 including Pauline Lapin from the CMS Innovation Center and speakers from HarmonyCares, CINQCARE, Bloom Healthcare, and Solventum who will discuss accountable care for complex populations. Register here.

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