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CMS Innovation Center Models — COVID-19 Related Adjustments (June 3, 2020)

Summary

A CMS Innovation Center Models COVID-19 Related Adjustments document dated 06/03/2020. It states that the table describes adjustments made or to be made to certain Centers for Medicare & Medicaid Services Innovation Center models to address the COVID-19 public health emergency (PHE), focusing on financial methodologies, quality reporting and model timelines. It lists principles used to determine appropriate changes, including utilizing existing flexibilities, minimizing reporting burden and aligning with national value based and quality payment programs. The table lists models, including one abbreviated CEC, with their financial methodology, quality reporting and timeline changes.

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“CMS Innovation Center Models — COVID-19 Related Adjustments (June 3, 2020).” Original at www.cms.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/ppr-int-69ed2691c4ddaad8-innovation-model-covid-19-adjustments-pdf-918-59161e0695/, SHA-256 10b04398eaa0347afd8e487ea71e77427134daea28d216d877db95fae5b90512.

Full text

 CMS Innovation Center Models COVID-19 Related Adjustments
The table below describes adjustments that have been made or that CMS will be making to
certain Centers for Medicare & Medicaid Services (CMS) Innovation Center Models to address the
COVID-19 public health emergency (PHE). The table specifically focuses on model adjustments
related to financial methodologies, quality reporting, and model timelines. The Innovation Center
model adjustments described here are not exhaustive; Innovation Center has already implemented
several changes and there is the potential for future adjustments, as the COVID-19 PHE continues to
evolve. Additional information about each of these model adjustments is available here
(https://innovation.cms.gov/innovation-models/covid-19-flexibilities).

We used the following principles to determine which changes are appropriate:
     • Utilize flexibilities that already exist in current model design
     • Continue sufficient financial incentives that encourage higher quality outcomes to
       participate in value based arrangements
     • Ensure equity and consistency across models
     • Align as much as possible with national value based and quality payment programs.
     • Minimize risk to both model participants, the Medicaid program, and the Medicare
       Trust Funds
     • Minimize delays in new model implementation while providing additional opportunities
       for participation in new models
     • Minimize reporting burden
     • Complements and builds off of new CMS COVID-19 PHE flexibilities as outlined in
       regulation and waivers

Additional information regarding the implementation of these changes will be provided to model
participants by CMS, and such changes may involve amendments to participation agreements and
other model documents. We also note that, based on the future evolution of the COVID-19 PHE,
there is a possibility that the implementation of new models may be further delayed.

This document supplements emergency rules and waivers granted under section 1135 of the Act
specifically to address the COVID-19 PHE. Additional information is available at:
https://www.cms.gov/About-CMS/Agency-Information/Emergency/EPRO/Current-Emergencies/
Current-Emergencies-page




                                                1
                                                                                     06/03/2020
   Innovation               Financial                          Quality                    Model
  Center Model         Methodology Changes                Reporting Changes          Timeline Changes
Bundled        • Option for Participants to        • No Change                    • No Change
Payments         eliminate upside and downside
for Care         risk by excluding Clinical
Improvement      Episodes from Reconciliation
Advanced         for Model Year 3 (2020)
               • For BPCI-Advanced Participants
                 that choose to remain in
                 two-sided risk, exclude
                 certain Clinical Episodes from
                 Reconciliation with a COVID-19
                 diagnosis during the episode
Comprehensive • Reduce 2020 downside risk          • Quality measure validation  • Extend model until
ESRD Care        by reducing shared losses by        deadline extended to May 4,   March 31, 2021
Model (CEC)      proportion of months during         2020
                 the PHE                           • Continue to monitor impact
               • Cap ESCOs’ gross savings            on 2020 quality reporting
                 upside potential at 5% gross
                 savings
               • Remove COVID-19 inpatient
                 episodes
               • Remove 2020 financial
                 guarantee requirement
Comprehensive • Remove downside risk by            • No Change                    • Extend
Care for Joint   capping actual episode                                             Performance
Replacement      payments at the target price                                       Year 5 through
(CJR) Model      for episodes with a date of                                        March 2021
                 admission to the anchor
                 hospitalization between
                 January 31, 2020 through the
                 termination of the emergency
                 period (as described in section
                 1135(e) of the Social Security
                 Act) (see CMS1744-IFC)
               • Extend the appeals timeline for
                 Performance Year (PY) 3 and PY
                 4 from 45 days to 120 days
Direct         • Adjust model to reflect           • Adjust quality benchmarks,   • Delay start of the
Contracting      change in duration of 2021          if necessary, to reflect       first Performance
(Global and      Performance Period due to           change in duration of 2021     Period for cohort
Professional)    April 1, 2021 start                 Performance Period due to      #1 to April 1, 2021
                                                     April 1, 2021 start          • Create application
                                                                                    cycle during 2021
                                                                                    for second cohort
                                                                                    to launch
                                                                                    January 1, 2022
                                                   2
                                                                                        06/03/2020
   Innovation                Financial                       Quality                        Model
  Center Model          Methodology Changes             Reporting Changes              Timeline Changes
Emergency      • No Change                      • No Change                         • Delay model start
Triage, Treat,                                                                        from May 1, 2020
and Transport                                                                         to Fall 2020
(ET3)
Home Health    • No Change                      • Align HHVBP Model data            • No Change
Value-Based                                       submission requirements
Purchasing                                        with exceptions or
Model (HHVBP)                                     extensions granted for the
                                                  HH QRP during the PHE for
                                                  COVID-19
                                                • Grant exceptions to the New
                                                  Measures data reporting
                                                  requirements under the
                                                  HHVBP Model during the
                                                  PHE for COVID-19. HHAs
                                                  are not required to report
                                                  New Measures data for
                                                  the following submission
                                                  periods: April 2020 and
                                                  July 2020.
Independence     • No Change                    • Allow IAH practices to utilize    • No Change
at Home                                           telehealth to meet quality
(Section 3024                                     metric requirements for 2 (of
of the ACA)                                       the 6 required) measures: 1)
                                                  48-hour follow-up visit post
                                                  hospital or ED discharge and
                                                  2) medication reconciliation in
                                                  the home.
Integrated Care • No Change                     • No Change                         • Delay first
for Kids (InCK)                                                                       quarterly
Model                                                                                 progress report
                                                                                      and associated
                                                                                      deliverables to
                                                                                      July 30, 2020.
Kidney Care      • Adjust model to reflect      • Adjust quality benchmarks,        • Delay start of the
Choices            change in duration of 2021     if necessary, to reflect            first Performance
                   Performance Period due to      change in duration of 2021          Period for cohort
                   April 1, 2021 start            Performance Period due to           #1 to April 1, 2021
                                                  April 1, 2021 start               • Create application
                                                                                      cycle during
                                                                                      2021 for second
                                                                                      cohort to launch
                                                                                      January 1, 2022



                                                3
                                                                                          06/03/2020
   Innovation                Financial                            Quality                    Model
  Center Model          Methodology Changes                  Reporting Changes          Timeline Changes
Maternal         • No Change                         • No Change                     • Delayed start
Opioid Misuse                                                                          of beneficiary
Model (MOM)                                                                            enrollment by six
                                                                                       months, until
                                                                                       July 1, 2021
Medicare Care • No Change                            • No Change                     • No Change
Choices Model
Medicare       • No Change                           • Extend deadline to submit     • No Change
Diabetes                                               quarterly Crosswalk file to
Prevention                                             July 15, 2020
Program
Expanded
Model (MDPP)
Medicare ACO • Remove episodes of care for           • 2019 Web Interface quality   • Voluntary
Track 1+ Model   treatment of COVID-19                 measure reporting deadline     election to extend
               • Medicare Shared Savings               extended from March 31, 2020   agreement for
                 Program Extreme and                   to April 30, 2020              1 year through
                 Uncontrollable Circumstances        • Medicare Shared Savings        December 2021
                 policy applies to 2020 financial      Program Extreme
                 reconciliation                        and Uncontrollable
                                                       Circumstances policy applies
                                                       to 2019 and 2020 reporting
                                                     • Continue to monitor impact
                                                       on 2020 quality reporting
Next             • Reduce 2020 downside risk         • 2019 Web Interface quality   • Extend
Generation         by reducing shared losses by        measure reporting deadline     model through
ACO (NGACO)        proportion of months during         extended from March 31, 2020   December 2021
                   the PHE.                            to April 30, 2020
                 • Cap NGACOs’ gross savings         • 2019 quality audit canceled
                   upside potential at 5% gross      • Continue to monitor impact
                   savings                             on 2020 quality reporting
                 • Remove episodes of care for
                   treatment of COVID-19
                 • Use retrospective regional
                   trend, rather than prospective,
                   for 2020
                 • Remove 2020 financial
                   guarantee requirement




                                                     4
                                                                                           06/03/2020
   Innovation                 Financial                             Quality                     Model
  Center Model           Methodology Changes                   Reporting Changes           Timeline Changes
Oncology Care     • Option for OCM practices            Make the following optional     • Extend model for
Model (OCM)         to elect to forgo upside and        for the affected performance      1 year through
                    downside risk for performance       periods:                          June 2022
                    periods affected by the PHE          • Aggregate-level reporting of
                  • For OCM practices that remain          quality measures
                    in one- or two-sided risk for the    • Beneficiary-level reporting
                    performance periods affected           of clinical and staging data
                    by the PHE, remove COVID-19         Remove the requirement for
                    episodes from reconciliation        cost and resource utilization
                    for those performance periods       reporting and practice
                                                        transformation plan reporting
                                                        in July/August 2020
Primary           • No Change                           • No Change                     • Delay
Care First—                                                                               implementation
Serious Illness                                                                           of the start of
Component                                                                                 the Performance
                                                                                          Period for the
                                                                                          Serious Illness
                                                                                          component until
                                                                                          April 1, 2021;
                                                                                          Primary Care First
                                                                                          only component
                                                                                          will still start on
                                                                                          January 1, 2021




                                                        5
                                                                                              06/03/2020


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