11 May HCTTF Recommendations to Support APM Participants During COVID-19
The Health Care Transformation Task Force (HCTTF or Task Force) wrote to the Centers for Medicare and Medicaid Services (CMS) to urge CMS to take specific actions to account for the impact of COVID-19 on alternative payment models and programs by providing relief for alternative payment model (APM) participants.
Task Force members provided recommendations for how APMs can be supported during the COVID-19 crisis and how APM operations and methodologies should be refined to mitigate the crisis’ impact in future years. The letter leads with near term proposals for immediate relief that will promote our shared goal of continued participation in APMs followed by proposals that help stabilize and improve APMs longer-term based upon experience provided care during the COVID-19 pandemic.
HCTTF recommendations
Near term proposals to support Medicare APMs
- The Task Force urges CMS to make APM infrastructure support payments from new funding vehicles to all model participants in the Medicare Shared Savings Program (MSSP) and all participants in models qualifying as Advanced APMs. This infrastructure support payment should take the form of a per beneficiary per month dollar amount equal to $28 per beneficiary for all PY2019 Qualifying APM Participants for a period of February 1st, 2020 and running for two months after a/the public health emergency declaration is lifted.
- HCTTF believes CMS should provide clear guidance about the intent to provide relief to providers impacted by COVID-19 that are participating in all Medicare APMs by May 15th.
- Current participants in shared savings models including the MSSP and Next Generation ACO (NGACO) model should be allowed to notify CMS by August 31st if they don’t wish to be financially reconciled nor held responsible for program requirements for the 2020 performance year without having to fully terminate their agreement.
- We recommend that CMS allow all MSSP ACO participants that wish to continue participation in PY2020 to have a choice between remaining in their current track, if higher, or electing the lower Basic Track Level B risk levels: 0% downside risk and up to 40% shared savings.
- The Task Force urges CMS to allow NGACOs to re-select their risk options including lowering the risk share beyond the 80 percent and 100 percent options currently available. CMS should also provide a one-year extension of the NGACO program through 2021.
- CMS should adopt an alternate approach to address the impact of COVID-19 on BPCI Advanced participants should the current “natural disaster” provision be deemed not applicable to the COVID-19 pandemic.
Additional recommendations to fortify value-based care and payment transformation
- CMS should waive payment and patient count thresholds and deem all entities participating in eligible Advanced APMs to have satisfied Qualifying APM Provider (QP) thresholds to be eligible to receive the 5% Advanced APM incentive payment for the 2020 performance year.
- HCTTF urges CMS to provide options to advance payments for any non-claims-based payment components of APMs financial models (e.g., care management fees, population-based payments), and accelerate the processing of shared savings and positive reconciliation payments.
- The Task Force urges CMS to consider making the 2020 performance year reporting-only for any quality measurement components that can be appropriately conducted and reported under pandemic conditions for APM models.