Entries in Provider Payments (47)

Friday
Oct122018

The State of BPCI

by Clive Riddle, October 12, 2018

CMS announced that “1,299 entities have signed agreements with the agency to participate in the Administration’s Bundled Payments for Care Improvement – Advanced (BPCI Advanced) Model.  The participating entities will receive bundled payments for certain episodes of care as an alternative to fee-for-service payments that reward only the volume of care delivered. The Model participants include 832 Acute Care Hospitals and 715 Physician Group Practices – a total of 1,547 Medicare providers and suppliers, located in 49 states plus Washington, D.C. and Puerto Rico.”

CMS also reminds us that “BPCI Advanced qualifies as an Advanced Alternative Payment Model (Advanced APM) under MACRA, so participating providers can be exempted from the reporting requirements associated with the Merit-Based Incentive Payment System (MIPS).”

CMS further explains these three differences between the new BPCI Advanced Model and the original BPCI Initiative that ended September 30, 2018:

  1. BPCI Advanced offers bundled payments for additional clinical episodes beyond those that were included in BPCI, including – for the first time – outpatient episodes.
  2. BPCI Advanced provides participants with preliminary target prices before the start of each model year to allow for more effective planning. The target prices are the amount CMS will pay for episodes of care under the model.
  3. BPCI Advanced qualifies as an Advanced APM.  Participating clinicians assume risk for patients’ healthcare costs and also meet other requirements including meeting quality thresholds, potentially qualifying them for incentive payments and exempting them from the MIPS program.

CMS has released results of its evaluation of the original BPCI Initiative, Models 2-4 for Years 1 -3 (through 12/31/2016.) CMS notes that “Model 2 episodes begin with a hospital admission and extend for up to 90 days; Model 3 episodes begin with the initiation of post acute care following a hospital admission and extend for up to 90 days; and Model 4 episodes begin with a hospital admission and continue for 30 days. The BPCI initiative rewards participants in Models 2 and 3 financially through reconciliation payments for reducing Medicare payments for an episode of care relative to a target price. Alternatively, when episode payments are higher than the target price, Awardees may have to pay amounts to CMS. Under Model 4, Medicare makes a prospective payment for the episode, so Awardees keep the difference if their costs are below the prospective payment.”

Of all participants, 22% of Model 2, 33% of Model 3, and 78% of Model 4 participants withdrew from the initiative.

CMS evaluation is based on the 169-page study just released by the Lewin Group: CMS Bundled Payments for Care Improvement Initiative Models 2­4: Year 5 Evaluation &  Monitoring Annual Report. Their findings included:

  • While BPCI was associated with a decline in episode payments, after considering the reconciliation payments made to participants, BPCI did not result in savings to the Medicare program.
  • Across the 67 Model- participant- and clinical episode-combinations analyzed in this report, payments declined for 50 and the change was statistically significant for 27.
  • The average Model 2 episode initiator (EI) participated in eight clinical episodes, and the most commonly selected clinical episode was MJRLE. BPCI Model 2 accounted for nearly 90% of the approximately 796,000 episodes initiated during the first 13 quarters of the initiative.
  • Episode volume was lower than in Model 2. Skilled nursing facility (SNF) EIs were most likely to participate in MJRLE, where they initiated over 9,600 episodes during the first 13 quarters of the initiative. Congestive heart failure (CHF) had the greatest enrollment of home health agency (HHA) EIs and the largest patient volume, exceeding 4,800 episodes during the same period.
  • Participation in Model 4 continued to wane in the third year of the initiative. Only five hospitals participated in Model 4 in 2017 and another three Model 4 hospitals transitioned to Model 2 rather than withdraw entirely from the initiative. At the peak of enrollment, 23 episode-initiating hospitals participated in Model 4. A total of 13,551 episodes, primarily for MJRLE, were initiated under the Model through December 2016.

 

Friday
Sep142018

Post ACA Operating Margins: Health Systems and Health Plans

By Clive Riddle, September 14, 2018

Navigant this week released an eight-page report: Stiffening Headwinds Challenge Health Systems to Grow Smarter, that provides “an analysis of a three-year sample of the financial disclosures of 104 prominent health systems operating 47% of U.S. hospitals,” in which Navigant  “found broad-based and significant deterioration of operating earnings.”

 

Navigant reports that from 2015 to 2017:

  • The average operating margin decline for analyzed systems was 38.7%. Not-for-profit system margins fell 34%, while for-profit margins fell 39%.
  • 65% of systems experienced operating income declines totaling $6.8 billion, with the most significant reductions occurring in the U.S.’s fastest-growing regions: West/Southwest and South Central.
  • At the root of these declines were multiyear reductions in the rate of topline operating revenue growth, which fell from 7% (2015 to 2016) to only 5.5% (2016 to 2017), and a failure to contain expenses in line with revenue deterioration. 

Navigant cites these drivers of earnings deterioration:

  1. Weakening demand for such core hospital services as surgery and inpatient admissions, due in part to rising patient cost exposure from high-deductible health plans;
  2. Deteriorating collection rates for private accounts in non-ACA expansion states;
  3. Steady erosion in Medicare payment rates due to the ACA and the 2012 federal budget sequester; and
  4. Failure of health system value-based insurance contracts to deliver sufficient patient volume to offset steep upfront payer discounts and significant hospital population health investments.

Meanwhile on the other side of the post-ACA equation, Mark Farrah Associates this week “released an analysis brief providing insights into mid-year profitability for commercial and government lines of health insurance business. MFA compared second quarter, year-over-year profitability for the Individual, Employer-Group, Medicare and managed Medicaid segments.”

They found that:

  • At the end of second quarter 2018, the average medical expense ratio for the Individual segment was 70.8%, as compared to 77.2% the previous year.
  • Growth in premiums pushed the average medical expense ratio for the Employer-Group segment down to 80.9% for 2Q18 from 81.8% in 2Q17.
  • For Medicare Advantage, premium growth outpaced increases in medical expenses pushing the medical expense ratio down to 85.3% from 86.1% in 2Q17.
  • 2.9% increase in premiums per member per month pushed the medical expense ratio for Managed Medicaid down to 88.6% from 91.0% in 2Q17.

Mark Farrah Associates concludes the current outlook is better than the one Navigant finds for health systems: “At the mid-year point, all four health care segments are signifying improved profitability for health insurers over 2017.  The most significant change is once again in the Individual segment showing improvement over 2017, which ended up being a profitable year for the segment overall.  While this analysis of mid-year segment performance sheds light upon profitability trends for 2018, it’s a wait and see proposition until final financial results are revealed in spring of 2019.”

Friday
Aug102018

25 Things to Know About The CMS Medicare ACO Proposed Rule: Pathways to Success

By Clive Riddle, August 10, 2018

Here are 25 major points to note in the CMS Pathways to Success Proposed Rule introduced on August 9th:

  1. The redesigned Medicare Shared Savings program is called “Pathways to Success.
  2. There are five stated goals Pathways to Success is intended to advance: Accountability, Competition, Engagement, Integrity, and Quality.
  3. The CMS projected financial impact of the proposal would be savings to Medicare of $2.2 billion over ten years.
  4. CMS notes that 460 of the 561 or 82% of all ACOs in the Shared Savings Program in 2018 – are not taking on risk for increases in costs.
  5. The amount of time that an ACO can remain in the program with upside-only risk  would be limited to two years (or one year for ACOs identified as having previously participated in MSSP under upside-only risk) instead of the current timetable of up to six years.
  6. A 6-month extension would be provided for current ACOs whose agreements expire at the end of 2018, along with a special one-time July 1, 2019 start date that will have a spring 2019 application period for the new participation options.
  7. The number of tracks would be reduced to two, the “BASIC” track and the “ENHANCED” track, and would allow providers to pick between these two tracks. 
  8. The length of ACO participation agreements would expand from three years to five years.
  9. The BASIC track would feature a glide path for taking risk.  It would begin with up to two years of upside-only risk and then gradually transition in years three, four, and five to increasing levels of performance risk, concluding in year five at a level of risk that meets the standard to qualify as an Advanced Alternative Payment Model (APM) under MACRA. 
  10. Current upside-only ACOs would be limited to one year without risk before being required to transition to the risk level in year three of the glide path.
  11. The ENHANCED track would allow providers to take on risk and qualify as an Advanced APM immediately.  This track would offer the same amount of risk for each of the five years of the agreement period, at a level of risk sharing higher than the maximum amount reached in the BASIC track.
  12. Eligible ACOs (ACOs that are inexperienced with two-sided risk in Medicare) would be able to enter at any level of risk in the BASIC track’s glide path or go straight to the ENHANCED track.
  13. After completing a five-year agreement under the BASIC track, low revenue ACOs would be able to renew for a second agreement period at the highest level of risk in the BASIC track, while high revenue ACOs would be required to move to the ENHANCED track and take on additional risk.
  14. Each ACO would provide a standardized written notice to its Medicare beneficiaries, informing them at their first primary care visit of a performance year that they are in an ACO and what that means for their care.
  15. CMS would allow certain two-sided ACOs to provide an incentive payment of up to $20 to each assigned beneficiary for each qualifying primary care service that the beneficiary receives, as an incentive for taking steps to achieve and maintain good health. 
  16. CMS is seeking comment on an approach that would allow beneficiaries to opt in to an ACO as an alternative to assignment. 
  17. CMS would streamline the measures that ACOs are required to report, to ensure that all measures have a meaningful impact on patient care.
  18. CMS would require a specified percentage of the eligible clinicians participating in an ACO to adopt the 2015 edition of Certified EHR Technology (CEHRT) as part of the Administration’s MyHealthEData initiative promoting interoperability of medical data and patient control of their data.
  19. Physicians in ACOs that take on risk could receive payment for telehealth services provided to patients regardless of the patient’s location.
  20. Regional (county-level) spending would be incorporated into ACO benchmarks starting in their first agreement period.
  21. Methodology for risk adjustment would more accurately account for changes in beneficiaries’ health status.
  22. When calculating and updating benchmarks, CMS would factor in national spending growth rates in addition to regional rates, so ACOs that constitute a large fraction of their local market would not be penalized if they reduce the market growth rate.
  23. ACOs in two-sided models would be accountable for losses even if they exit mid-way through a performance year.
  24. Termination of ACOs with multiple years of poor financial performance would be authorized.
  25. The detailed Medicare Shared Savings Program Notice of Proposed Rulemaking (CMS-1701-P), “Accountable Care Organizations‑‑Pathways to Success,” is available at https://www.federalregister.gov/public-inspection/  and https://www.cms.gov/newsroom/fact-sheets/proposed-pathways-success-medicare-shared-savings-program.

 

Thursday
Apr122018

Long Term ACO Impact: Medicare vs. Medicaid vs. Commercial

Long Term ACO Impact: Medicare vs. Medicaid vs. Commercial
 

By Clive Riddle, April 12, 2018

 

Commercial accountable care – value based payment arrangements between purchasers and providers seem to be spreading virally. States Medicaid accountable care initiatives are proliferating.  Will Medicare continue to consumer the greatest share of healthcare stakeholder attributed ACO patients and financial resources?  The April issue of Accountable Care News Thoughtleaders Corner ask a panel this question: “Which type of ACO activity will have more impact on stakeholders in the long term: Medicare, Medicaid  or commercial?”

 

Kirit Pandit, Co-Founder & Chief Technology Officer of VitreosHealth responds that “I think Medicare ACO activity will have the most impact in the long term based on where incentives are maximized. Fully capitated plans such as Medicare Advantage and managed Medicaid plans will have the highest incentive to reduce costs and maintain high quality scores. This is where ACO activity will produce the best outcomes. The per member per month costs are high to make it attractive for providers to participate in these performance-based contracts.  However, compared to Medicare ACOs, Medicaid has higher churn rates. This makes it challenging for the providers to manage these members with a long-term perspective. If the churn rates are high, chronic care management activities will not have enough time to impact patient behavior and outcome. So the Medicare ACO plans that are fully capitated and have minimal member churn will have the highest impact.”

 

 Michael Millenson, President, Health Quality Advisors; adjunct associate professor of medicine at Northwestern University’s Feinberg School of Medicine and author of the book Demanding Medical Excellence has this to say: “Right now, it’s synergistic. Medicare is by far the nation's largest payer, but joining an ACO is voluntary. However, Medicare’s clout and standardization are critical. On the other hand, Medicaid and private payers can both push their programs on providers (a state or large employers can choose only ACOs) and be much more innovative. Statutorily, CMS could switch all Medicare to ACOs without additional congressional authorization. If that ever happens – with implicit Congressional approval and definitely in the long term – this question will have answered itself.”     

 

William DeMarco, Founder and President, Pendulum HealthCare Development Corporation, which has advised a wide range of ACO clients shares that “We think after all the dust settles, Medicare will offer the biggest impact on stakeholders. This considers total dollars and the fact that 10,000 Baby Boomers turn 65 every day and total cost of care will continue to rise ahead of inflation – so it will always be a big number. Medicaid will continue to be in a constant state of change on a state-by-state basis, but will slowly follow the ACO transition that may very well lead to more Special Needs and Dual-Eligible strategies being promoted by states and offered by insurers, as well as provider-led health plans that see the advantage of receiving a large capitated sum from Medicare and Medicaid for eligible patients. I say this based upon the number of Section 1115 waivers being sought to permit states to offer above and beyond Medicaid benefits through ACOs and CCOs. Commercial will always be in transition, as self-funded and fully insured are finding big deductibles do not work and the fiduciary accountability starts to weigh heavily on many of the purchasers of care. What employers are interested in are ACOs that can manage the active workers and retirees at a predictable cost. Health plans and insurers are seeing their profitability is linked with these ACOs that can take partial or full risk for the medical portion of the premium, and this allows the health plan to improve administrative cost savings – plus predict total cost of care.”

 

So, some collective wisdom seems to point towards Medicare continuing to hold the strongest magnetic force attracting ACO activity.

 
Friday
Jan192018

2018 CMS Medicare Shared Savings Program: 43 Previous ACOs out, 124 New ACOs In

By Clive Riddle, January 19, 2018

CMS recently published 2018 Medicare Shared Savings Program information.  After comparing the listing of 561 2018 MSSP participants to the 480 2017 participants, we found 43 2017 ACOs have exited the program for 2018, and there are 124 new ACOs for 2018.  Caravan Health has sponsored 15 new ACOs, and Community Health Systems is sponsoring 14 of the new ACOs.

Here’s the list for the 43 ACOs exiting the program:

  1. Accountable Care Coalition of Mount Kisco (CT, NY)
  2. Accountable Care Coalition of Western Georgia (AL, GA)
  3. ACO of East Hawaii (HI)
  4. Advanced Premier Physicians ACO (CA)
  5. APCN-ACO (CA)
  6. ApolloMed Accountable Care Organization (CA, FL, HI)
  7. Arkansas High Performance Network ACO of FQHC (AR, KY)
  8. Arkansas HIgh Performance Network ACO (AR)
  9. Bay Area Medical Associates ACO (CA)
  10. Bluegrass Clinical Partners (FL, KY, TN)
  11. Care Covenant (TX)
  12. Catholic Medical Partners-Accountable Care IPA (NY)
  13. CHRISTUS Louisiana ACO (LA)
  14. CHWN ACO (IL)
  15. Collaborative Health ACO (MA)
  16. Community Health Accountable Care (NH, NY, VT)
  17. Connected Care (MI)
  18. Cornerstone Health Enablement Strategic Solutions (NC)
  19. Health Leaders Medicare ACO Network (LA)
  20. Indiana Care Organization (IN)
  21. Kansas Primary Care Alliance (KS, MO)
  22. KCMPA-ACO (KS, MO)
  23. Mary Washington Health Alliance. (VA)
  24. Mercy ACO (AR, MO)
  25. MHT-ACO (GA, MI, OK, SC, TX)
  26. Midwest Quality Care Alliance (KS, MO)
  27. NEQCA Accountable Care, (MA)
  28. North Jersey ACO (NJ, NY)
  29. OneCare Vermont Accountable Care Organization (NH, VT)
  30. Oregon ACO (OR, WA)
  31. Palm Accountable Care Organization (FL)
  32. Physicians Accountable Care Solutions (CA, CO, CT, IL, NY, OH, PA, UT, WV)
  33. Physicians Collaborative Trust ACO (FL)
  34. Primaria ACO (IN)
  35. Primary Care Alliance (FL)
  36. Revere Health (AZ, UT)
  37. Shannon Clinic (TX)
  38. South Shore Physician-Hospital Organization (MA)
  39. SPACO (FL)
  40. Torrance Memorial Integrated Physicians (CA)
  41. UW Health ACO, (WI)
  42. VirtuaCare (NJ)
  43. Western Maryland Physician Network (MD, PA, VA, WV)

And here’s the list of the 124 new ACOs joining the program for 2018:

  1. Accountable Care Coalition of Alabama (AL)
  2. Account. Care Coal. of Community Health Centers (AR, DC, FL, IL, KY, MD, MI, RI)
  3. Accountable Care Coalition of New Jersey (NJ)
  4. Accountable Care of Nevada (NV)
  5. Accountable Care Organization of Aurora (IL, MI, WI)
  6. ACO West Virginia (PA, WV)
  7. Acorn Network (IL, IN, MI)
  8. Adventist Health Accountable Care (CA)
  9. Adventist Health System ACO (FL)
  10. Alabama Physician Network (AL)
  11. Aledade Accountable Care 22 (OH, PA)
  12. Aledade Accountable Care 25 (NJ)
  13. Aledade Accountable Care 35 (LA, MS, TN)
  14. Aledade Accountable Care 37 (MD, TN, VA, WV)
  15. Baptist Health/UAMS Accountable Care Alliance (AR, TX)
  16. Baptist Physician Partners ACO (FL, GA)
  17. Bethesda Health Quality Alliance (FL)
  18. Boulder Valley Care Network (CO)
  19. Bridges Health Partners ACO (PA)
  20. Caravan Health ACO 11 (AL, GA, IL, KY, NM, NV, TX)
  21. Caravan Health ACO 12 (MN, WI)
  22. Caravan Health ACO 13 (MA, NY, VT)
  23. Caravan Health ACO 14 (ID, MN)
  24. Caravan Health ACO 15 (IA, MN, NE, SD)
  25. Caravan Health ACO 16 (AL, TN)
  26. Caravan Health ACO 17 (OR)
  27. Caravan Health ACO 31 (OK)
  28. Caravan Health ACO 32 (OK)
  29. Caravan Health ACO 33 (OK)
  30. Caravan Health ACO 34 (OK)
  31. Carolinas HealthCare System ACO (NC, SC)
  32. Cascadia Care Network (WA)
  33. Centrus Health of Kansas City (KS, MO)
  34. CHSPSC ACO 1 (AL, FL, LA, MS)
  35. CHSPSC ACO 10 (FL)
  36. CHSPSC ACO 12 (GA, NC, SC, VA)
  37. CHSPSC ACO 13 (PA)
  38. CHSPSC ACO 14 (TN, WV)
  39. CHSPSC ACO 15 (KY, TN)
  40. CHSPSC ACO 16 (OK)
  41. CHSPSC ACO 17 (FL)
  42. CHSPSC ACO 2 (IN)
  43. CHSPSC ACO 21 (AL, FL)
  44. CHSPSC ACO 6 (TX)
  45. CHSPSC ACO 7 (AR, LA, MO, OK)
  46. CHSPSC ACO 8 (AK, AZ, NM, NV)
  47. CHSPSC ACO 9 (IN)
  48. Coastal One Health Partners (CA)
  49. ColigoCare (NJ, NY)
  50. Community Health Center Network Of Idaho (ID, OR, WA)
  51. Community Healthcare Partners ACO, (IL, IN)
  52. Connected Care of East Tennessee (AL, GA, TN)
  53. Connected Care of Middle Tennessee (TN)
  54. Connected Care of Mississippi (MS)
  55. Connected Care of West Tennessee (MS, TN)
  56. CPSI ACO 2 (CA, CO, GU, ID, ND, OR, SD, WA)
  57. CPSI ACO 3 (GA, MS, NC)
  58. CPSI ACO 7 (IA, IL, NE, WI, WV)
  59. CPSI ACO 8 (AR, LA, MO, TX)
  60. Crestwood Regional Healthcare Alliance (AL)
  61. CVACC (VA)
  62. DMH Health Network (IL)
  63. DOCACO GULF COAST (FL, SC)
  64. Einstein Care Partners (PA)
  65. Family Choice ACO (CA)
  66. Foothill Accountable Care Medical Group, (CA)
  67. Genesis Physicians Group (TX)
  68. Health Alliance ACO (DC, MD, VA)
  69. Healthcare Quality Partners (NJ, PA)
  70. HealthChoice (AR, MS, TN)
  71. Heritage Valley Healthcare Network ACO (OH, PA, WV)
  72. Holy Name Medical Center ACO (NJ)
  73. HP2 (GA)
  74. Independent Physicians Accountable Care (CA, CT, FL, SC, TX, VA)
  75. Inspire Health Partners (IN)
  76. Intermountain Accountable Care (NV, UT)
  77. Keep Well ACO (IL, KS, MO)
  78. KENNEDY HEALTH ALLIANCE (NJ)
  79. Kootenai Accountable Care (ID, WA)
  80. McFarland Clinic, PC (IA)
  81. McLeod Healthcare Network (NC, SC)
  82. MHC Accountable Care Organization (KY, OH, WV)
  83. MHN ACO (IA, IL, NE, SD)
  84. MSHP ACO (NY)
  85. MultiCare Connected Care (WA)
  86. NCH ACO (FL)
  87. NorthShore Physician Assoc. Value Based Care (IL)
  88. OhioHealth Venture (OH)
  89. Orange Accountable Care Organization (FL, MD, NJ, NM, PA, TX)
  90. Pacific Private Practice Network, Inc (CA, TX)
  91. PathfinderHealth (AZ)
  92. Physician Partners of Western PA (PA)
  93. Physician Performance Network of Arizona (AZ)
  94. Primary Comprehensive Care ACO (IL, NC)
  95. PRIMARY PARTNERS (FL)
  96. PRIME ACCOUNTABLE CARE WEST (AZ, CA, IL, NV)
  97. Privia Quality Network Gulf Coast II (TX)
  98. QHI ACO (CA, CT, IL)
  99. Renaissance Physicians Accountable Care (TX)
  100. Riverside Health Source (VA)
  101. Rush Health ACO (IL)
  102. Saint Francis Hospital Medicare ACO (AR, IL, MI, MS, TN)
  103. Select Physicians Associates (AL, FL)
  104. SIGNATURE NETWORK (VA)
  105. Space Coast Independent Practice Association (FL)
  106. St. Dominic Medical Associates (MS)
  107. St. Luke's ACO (IL, MO)
  108. St. Luke's Medicare ACO (NJ, PA)
  109. St. Tammany Hospital ACO (LA)
  110. Steward National Care Network, (FL, MA, NJ, OH, PA)
  111. The Iowa Clinic, P.C. (IA)
  112. The Ohio State Health ACO (OH)
  113. Treasure Coast Integrated Healthcare (FL)
  114. UC Davis Health ACO (CA)
  115. UC Irvine Health Accountable Care Organization (CA)
  116. UC San Diego Health Accountable Care Network (CA)
  117. UCSF Health ACO (CA)
  118. UMC Accountable Care (NM, TX)
  119. United Physicians ACO (MI)
  120. University Health ACO (TN)
  121. UPQC (NV, UT)
  122. Valley Medical Group-Renton (WA)
  123. VillageMD Chicago ACO (GA, IL, IN, KY, TN)
  124. White River Health System Clinically Int. Network (AR)