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:

  • Convened the Total Cost of Care committee to discuss comments on the Medicare Physician Fee Schedule proposed rule.
  • Attended several meetings with the CMS Innovation Center to discuss the ACO REACH model and the Request for Information related to development of a new track of the Medicare Shared Savings Program with higher levels of risk and reward
  • Convened A4H members to discuss recent guidance related to significant, anomalous, and highly suspect billing.
  • Hosted an A4H member meeting with McDermott Will & Emery on the Supreme Court’s recent decision to overrule Chevron deference and discuss the implications for value-based care.

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Congressional News

The House has recessed until September 9. The Senate will be in session next week before departing for the August recess.

MedPAC Releases Annual Data Book. The Medicare Payment Advisory Commission (MedPAC) released its annual Data Book. The Data Book provides charts, tables, and graphs describing the Medicare program’s utilization and payment systems. Section 5 of the Data Book takes a closer look at Alternative Payment Models. Some takeaways:

  • Three-fourths of the 61 million Medicare beneficiaries are in managed care plans (Medicare Advantage or other private plans) or are assigned to accountable care organizations.
  • The number of beneficiaries assigned to MSSP ACOs grew rapidly through 2018 and then leveled off.
  • Comprehensive Care for Joint Replacement is Medicare’s largest episode-based payment model, with 324 participating hospitals in 2024.
  • Nearly 90 percent of the clinicians who qualified for the advanced APM bonus were in the Medicare Shared Savings Program.
  • Among all primary care physicians who billed FFS Medicare in 2022, 77 percent participated in an MSSP ACO.
  • Among other specialties, participation in ACOs as a share of all clinicians within the specialty varies greatly. For example, 59 percent of all pulmonologists participating in FFS Medicare in 2022 also participated in an ACO. By contrast, less than 30 percent of ophthalmologists and dermatologists participated in an MSSP ACO.

As the Medicare advisors for Congress, lawmakers and staff utilize MedPAC’s analysis to help inform policy development, including informing the future of the advanced APM bonus and recommendations around future APMs.

Administration

CMS Releases Year 4 Results for ESRD Treatment Choices (ETC) Model. The ETC model is a mandatory payment model intended to encourage greater use of home dialysis and kidney transplants for Medicare beneficiaries with end stage renal disease (ESRD). A summary of the results can be found here, and the ETC webpage can be found here. In general, ETC participants showed improved rates of home dialysis and transplants over time. Forty-one percent of eligible ESRD facilities and 56 percent of eligible managing clinicians received a positive performance payment adjustment (PPA).

CMS Extends Application Period for ACO PC Flex. The new submission deadline for the ACO Primary Care Flex Model (ACO PC Flex Model) is August 23, 2024; the previous deadline was August 1. The five-year model is a new primary care payment for low-revenue ACOs in the Shared Savings Program. The application portal is available here, and a fact sheet on the model can be found here.

Resources

CMMI Director Fowler Joins Podcast on the Future of Specialty and Primary Care Integration. In the “Health Podyssey” podcast hosted by Health Affairs, CMMI Director Liz Fowler called for bundled payments and financial incentives for specialists to affiliate with ACOs and move toward value-based care. She also highlighted the incentive for specialists to stay in fee-for-service, emphasized the potential role of mandatory models, and stressed the importance of establishing a set of value-based incentives under which providers should operate. Director Fowler acknowledged challenges related to multi-payer alignment and noted it is a priority in CMMI’s strategy refresh to help practices move toward value-based care; she promoted the Making Care Primary (MCP) Model, the States Advancing All-Payer Health Equity Approaches and Development (AHEAD) Model, and the Health Care Payment Learning and Action Network (LAN).

Town Hall Ventures Highlights New Value-Based Care Initiatives in CY25 PFS. The post, highlights new value-based care (VBC) proposals in the Calendar Year 2025 Physician Fee Schedule. The article dives into several changes incorporating VBC principles into traditional fee-for-service (FFS) settings. The highlights:

  • Advanced Primary Care Management: New payment structures to support comprehensive care management.
  • Prepayments and Health Equity Benchmark Adjustments: Upfront financial resources for ACOs focused on underserved communities.
  • Expanded Telehealth Definitions: Including audio-only telehealth visits to broaden access.

The authors conclude CMS is creating more opportunities for providers through these changes and making VBC more mainstream.

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, and Bloom Healthcare who will discuss accountable care for complex populations. Register here.

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