May 15, 2020

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On Wednesday May 6, Caravan Health hosted a webinar to review the details of the latest CMS regulatory package responding to the COVID-19 pandemic. Read our high-level summary of the rule here. On this webinar, Caravan President and CEO Tim Gronniger led the discussion focused on the significant relief from ACO losses and potential costs from the pandemic. Dr. John Findley discussed the additional telehealth and virtual care flexibilities. The webinar recording is available here.

This latest rule provides a wide-ranging plan for helping accountable care organizations manage the crisis brought on by the COVID-19 pandemic. The new rules and waivers make it easier for ACOs to focus more on the health of their patients and practitioners and less about financial factors and moving to risk. Many of these changes are a welcome improvement from the initial CMS regulatory package, which had a narrower approach to ACO relief and telehealth improvements.

In response to the new rule and provisions, Caravan Health is preparing a comment letter and our analysis of some of the changes is below.

Any health systems, physician groups, or other providers who were planning to join the program in January can still join a Caravan Health collaborative ACO – for more information contact us at info@caravanhealth.com.

More Telehealth Fixes and Flexibilities
Caravan Health is encouraged to see CMS continue to ease the way for providers to adopt telehealth and virtual care. For the foreseeable future, these remote visits will be critical to maintaining patient health and managing a “second wave” health crisis from delayed preventive and acute care for non-COVID-19 conditions. Allowing telehealth services through audio connection, rather than requiring audio-visual, will make a significant difference in rural areas where telecommunications are not always strong or reliable. The expanded access to COVID-19 testing, without a doctor’s order, is an additional step in the right direction to improve health and help our communities return to a new version of normal.

Great Start on ACO Changes, but the Shared Savings Program Will Need More to Weather the Crisis
The major changes affecting MSSP ACOs are generally good news, especially the limit on shared losses for 2020 and the freezing of risk levels for 2021. ACOs should not have to weigh the pros and cons of a new risk arrangement during the pandemic. The new rule will also exclude COVID-19 costs connected to an inpatient stay from the ACO financial methodology. This prevents these temporary high costs from affecting benchmark or ACO expenditure calculations.

Caravan developed an example that demonstrated a hypothetical result from excluding these costs and how it could affect expenditures and benchmarks in high and low COVID-19 areas. Without the exclusions, benchmarks would rise in all areas, whether high and low incidence of COVID-19, due to COVID-related costs nationwide. Excluding those costs brings benchmarks down across the country, ensuring that no ACO earns a “windfall” from a higher than usual benchmark. Excluding these costs will also help protect against losses in heavily impacted areas. CMS will also disregard all ACO losses for the duration of the public health emergency. With both these policies in place, ACO losses should be minimized for much, if not all, of 2020.  



Another set of scenarios shows how benchmarks are affected by both (1) reduced volume from decreased Medicare costs and utilization and (2) increased Medicare costs and utilization from hard-hit COVID-19 areas. The new rule addresses the increased costs from COVID-19 care that could raise benchmarks but unfortunately does not include a solution for the decreased utilization and expenditures that could lower benchmarks and make them harder to beat and earn shared savings.
 


We look forward to seeing a few other changes that could help ACOs to come out of this crisis stronger than ever.  
 
  • Disregarding any quality data for 2020, since differentiating quality when primary care volume is plummeting, and many practices are moving to virtual care is near impossible.
  • Instead of focusing on traditional ACO savings, losses, and quality measures, reward ACOs to focus on specific tasks that makes best use of their primary care and care management capabilities.
 
These proposals would keep ACO practices focused on primary care delivery and innovation when volume is nosediving. It is imperative to keep the nearly 500,000 physicians and other clinicians already in ACOs working together during a crisis, maintaining the infrastructure that has already been built. Instead of the traditional ACO incentives, these practices need upfront resources to manage patients whose conditions could deteriorate in the coming months, potentially catching them before we face a second wave of serious illness resulting from deferred preventive care. 

Visit our COVID-19 Resources Page

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