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CMMI Announces New Policies for Innovation Center Models and COVID-19

June 5, 2020

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CONTACTS
Erin Hahn, Health Policy Analyst, Value Based Care
Phoebe Ramsey, Sr. Regulatory Analyst, Quality & Payment Policy

CMMI Announces New Policies for Innovation Center Models and COVID-19
The Centers for Medicare and Medicaid Innovation Center (CMMI) announced on June 3 new policies related to COVID-19 and CMMI’s value-based care models.

The policies are designed to remove financial and administrative burdens from participants. Many hospitals have needed to redirect their attention to better prepare for and/or treat COVID-19.

While several caveats were introduced in the first and second interim final rules (IFCs) for the Medicare Shared Savings Program (MSSP) and the Comprehensive Care for Joint Replacement (CJR) Model, the majority of CMMI model policies were introduced through the communication released from CMMI.

Accountable Care Organizations (ACOs)
The CMMI announcement included new policies for the MSSP Track 1+ Model and the Next Generation ACO Model, building on the separate MSSP policies announced in the IFCs. The IFCs clarified the MSSP extreme and uncontrollable circumstances policy, which reduces downside risk proportionate to the number of months during which the public health emergency (PHE) occurs. The CMMI announcement confirmed that the MSSP policy would apply for ACOs participating in the Track 1+ Model. For example, if the PHE were to last 6 months, then downside risk would be reduced by 50%, and if it were to last 12 months, downside risk would be reduced by 100%.

The IFCs also remove expenditures related to COVID-19 episodes of care, postpone the quality reporting deadlines, and provide a one-year extension to agreements ending December 2020. Under the June 3 CMMI announcement, the Next Generation ACO Model will implement similar policies by removing COVID-19 episodes of care, reducing downside risk proportionate to the duration of the PHE, and extending quality measure reporting deadlines.

Additionally, CMMI will cap the gross savings of Next Generation ACOs at 5% and will adjust the payment methodologies by applying a retrospective regional trend factor for 2020 rather than a prospective trend. CMMI will also remove the financial guarantee requirements for the 2020 performance period, and the agency canceled the 2019 quality audits. Lastly, the Next Generation ACO Model will be extended through December 2021 to account for the agency’s decision not to open a 2021 MSSP application cycle.

Bundled Payments
CMMI announced new policies for several bundled payment models. Participants in the Bundled Payments for Care Improvements (BPCI) Advanced Model will have a choice between opting out of both upside and downside risk for the current model year (2020) or remaining in a two-sided risk model with all COVID-19 clinical episodes carved out. CMMI will implement a similar policy for the Oncology Care Model (OCM), allowing participants to opt between the removal of upside and downside risk or a carveout of COVID-19 episodes of care during performance periods affected by the PHE. In addition, the OCM will waive the reporting requirements during periods affected by the PHE, and the model will also be extended for one year. The CJR model was addressed in the IFCs, which removed downside risk for episodes occurring during the PHE and extended the model by three months.

New CMMI Models
Several new CMMI models have had start dates and implementation deadlines delayed.

Kidney Care First, as well as the Direct Contracting Model and the Kidney Care Choices Model, will begin on April 1, 2021, postponed from the original start date of January 1, 2021. The Primary Care First Model will begin as planned on January 1, 2021, but one component of the model for seriously ill patients will be delayed until April 1, 2021. CMMI also announced modifications to the Comprehensive ESRD Care Model; the Medicare Diabetes Prevention Program Expanded Model; the Medicare Care Choices Model; the Maternal Opioid Misuse Model; the Integrated Care for Kids Model; the Independence at Home Demonstration; the Home Health Value-Based Purchasing Model; and the Emergency Triage, Treat, and Transport Model.

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