Introduction The stated goal of the Medicare Shared Savings Program (MSSP) is to lower the rate of growth in healthcare spending while improving patient access to quality care. (12) MSSP Accountable Care Organization (ACO) progress toward this goal of achieving savings or reducing expenditure growth has proven controversial, in part because there are a variety of ways to measure savings that may generate different results. In this report, we describe the Dobson | DaVanzo team approach13 to measuring MSSP savings and contrast this with reported findings from CMS. We also compare our results to other published work. Dobson | DaVanzo & Associates was commissioned by the National Association of Accountable Care Organizations (NAACOS) to conduct an independent evaluation of MSSP ACO cost savings. The CMS method of measuring ACO performance is based on an administrative formula that creates spending targets constructed with ACOs’ historical expenditures that are used to determine whether they will receive bonus payments. It is problematic when this financial target setting approach is used as if it were a program evaluation. Indeed, when independently evaluating both the Pioneer ACO and Next Generation ACO programs, CMS contractors used a difference-in-differences regression approach to estimate savings rather than the CMS benchmarking methodology used to set financial targets and calculate bonuses or penalties. (14,15). The CMS benchmarking methodology addresses the question “How has ACO spending changed compared to prior years’ spending?” While this may be an appropriate way to set performance benchmarks, it produces a biased estimate of program savings when compared to what may have occurred in the Medicare Fee-for-Service market had the ACO program not been in place. Instead, evaluation of program savings should incorporate a carefully designed comparison group or counterfactual to account for prevailing trends in order to address the question: “How have ACOs changed expenditures compared to other providers not participating in the ACO program?” Read the complete report from National Association of ACOs, here.Given the release of the NPRM and the October 16th deadline for comments with an expected ‘go live’ date in early 2019, the Florida Association of ACOs (FlaACOs) upcoming annual meeting in Orlando is a timely event to compare notes and process the impact of CMS’ proposed changes with your peers. For those of you in the Southeast with an interest in ACOs or valued based healthcare models and their performance in the greater Florida market, take note the Florida Association of ACOs (FlaACOs) convenes in Orlando, October 18th and 19th for their fourth annual meeting. This year’s impressive faculty line-up and agenda include a keynote presentation by former Health and Human Services Chief Technology Officer Todd Park. For the 5th year in a row, Health Innovation Media, publisher of ACO Watch, including Fred Goldstein, President, Accountable Health, LLC and me will be onsite interviewing keynote faculty and select participants at the FlaACOs conference. A video recap of last year’s gathering is here, as are two recent interviews with Farzad Mostashari, MD, CEO Aledade, and David Bjork, CEO, Commonwealth Health Advisors. Wednesday, September 12th at 3PM Eastern, 12 Noon Pacific, we chat with FlaACOs CEO and founder Nicole Bradberry on PopHealth Week. Join us! ==##==
It’s been a while since my last post. I hope everyone is enjoying their summer. In California we’re dealing with very serious wildfire threat. Please hold space in your thoughts and prayers for all of those in harms way – especially the first responders putting their lives on the line for people, their animals and property.
Today, while scanning my twitter stream, I noticed a thread by Farzad Mostashari, MD, co-founder and CEO of ACO management company Aledade.
Considering the drift we’re experiencing in the absence of health policy clarity, the former National Coordinator for Health Information Technology offers his insights via this medium to senior health policy officials including Health and Human Services (HHS) Secretary Alex Azar and Seema Verma, Administrator of the Centers for Medicare and Medicaid Services (CMS).
Since the election of 2016 and preceded principally by Republican leadership bully pulpit messaging of an impending material health policy shift enabled via non-stop ‘ObamaCare is failing’ narratives – proffered by Donald Trump and echoed relentlessly by a mostly health policy illiterate Congress – we’ve been in a conflicted state as to the likely directional vectors reforming our ‘cottage’ industry’s $3.3 trillion spend in 2016 with a per capita $10,348 figure, accounting for 17.9% of U.S. Gross Domestic Product.
This is troublesome given the absence a clear path or unified agenda according to CMS:
‘under current law, national health spending is projected to grow at an average rate of 5.5 percent per year for 2017-26 and to reach $5.7 trillion by 2026. While this projected average annual growth rate is more modest than that of 7.3 percent observed over the longer-term history prior to the recession (1990-2007), it is more rapid than has been experienced 2008-16 (4.2 percent).
In the recent survey titled ‘Third annual study of physicians and health plan executives‘ Quest Labs discloses ‘stalled progress on the road to value based healthcare, noting that 67% of health plan executives and physicians believed the U.S. has a fee-for-service healthcare system versus a value-based care system (27%).
This is noteworthy given several decades of ‘managed care innovation’ designed to advance the value based healthcare agenda. Clearly there is and has been resistance to this shift, health policy benchmarks advanced by HHS and CMS notwithstanding.
Now back to today’s timely thread advanced by Dr. Mostashari – the context for which is ACOs skittish over MSSP rule delay as CMS silence creates mounting uncertainty c/o @DB_Sweeney at Fierce Healthcare.
It’s July 30, which is a hugely significant date to ACOs- It’s normally the day before the deadline to submit applications to @CMSGov for new and renewing ACOs. But the whole cycle has been delayed waiting for @OMBPress to get the MSSP proposed rule out.
The administration has committed to accelerating the pace of alternative payment models and making improvements to shared savings programs. @SecAzar has appointed @AdamCMMi to help accelerate value-based payments. @SeemaCMS has spoken clearly about the need for reforms.
The ACO notice of proposed rule making was received at OMB on May 1, nearly 3 months ago! This is what regulatory uncertainty looks like, and it’s hurting physician practices and businesses who are waiting to make significant financial decisions. @MickMulvaneyOMB
There are thousands of physician practices who are weighing whether to move towards what congress asked them to do in #MACRA- move away from fee for service and towards alternative payment models. In many cases, physician-led ACOs are being weighed against joining the hospital.
There are hundreds of practices who are finishing their existing ACO contract periods and considering whether they move to 2-sided risk models as per admin pref, or drop out of the program, depending on whether the benchmark problems and unpredictability have been addressed.
These delays mean that ACOs will have a very short amount of time to make financially significant decisions in great uncertainty.
Every day of delay at OMB magnifies the probability of fewer physicians taking on advanced alternative payment models
That would be an “own goal”.
Recent converts notwithstanding, those of us who’ve been at this re-tooling or paradigm shift away from volume to ‘value based’ incentives – via a series of innovative delivery system models – for a while do get that ‘healthcare is complicated’. So aligning the stakeholders to move the needle from volume to value is a condition precedent in an already transformation resistant ecosystem.
Let’s keep it up and weigh in via this and other social mediums to keep the pressure on health policy leadership!
Unlike many in the conversation on social media including the likes of Twitter, Facebook, LinkedIn and blogs such as ACO Watch, I have been active in the health reform exchange of ideas since registering my twitter handle @2healthguru in August of 2008. My participation has been of the ‘sweat equity’ variety vs. those who are compensated for their content, curation or advocacy.
Many of us in the healthcare space (both clinical and administrative) are addicted to the industry and find it difficult if not impossible to exit whether physically or emotionally. Some commit out of a sense of mission, giving back or being of service, while others for the economic upside this vast ecosystem (which I have labeled the healthcare borg resisting any attempt to materially restrain its appetite) affords to exploit low hanging fruit from a fragmented, inefficient and unwieldy financing and delivery system. Many have personally enriched themselves via the frequent churn of asset ownership (hospitals, nursing homes, imaging centers, ambulatory surgery centers, etc.) or via niche solutions with little to no sustainable value followed by quick exits and generous investor returns.
This timing of my entry into social media was co-incident with the deliberative process that ultimately rendered unto the American public what was merged as the Affordable Care Act (ACA),
In the early days of twitter those of us active in the community spoke of the ‘addictive’ nature of twitter engagement, some even referred to this virtual community as ‘the matrix’. Bonds were formed, some of which remain intact to this day.
The ‘Fictional’ Obamacare ‘Disaster’
This morning Donald J, Trump aka the POTUS weighed in on the failed efforts of Senate GOP leadership to advance the Better Care Reconciliation Act of 2017 as amended by Senator Ted Cruz to the Senate floor. He said:
That this man continues to minimally misrepresent and worse intentionally lie to the American public is beyond the capacity for many to comprehend. From the American Academy of Actuaries to the Non-partisan Congressional Budget Office and multiple authorities in the underwriting to delivery space including risk bearing provider organizations and integrated delivery systems the narrative is quite to the contrary.
And where there is evidence of market instability or ‘failure‘ there is explanation including serial GOP initiatives to undermine the Affordable Care Act specifically with respect to ‘qualified health plans‘ (QHPs) listed on State run or Federally Facilitated Marketplaces (FFM) aka ‘Exchanges.’
The ‘death spiral‘ or ‘disaster‘ narrative is principally vested in the following argument:
- Major health plans and regional players who initially developed individual market product(s), i.e., benefit plans, and associated provider networks including premiums) for these exchanges are withdrawing participation from select markets.
- Premiums for some QHPs have increased by 100% or more on select exchanges; and
- In some states and select counties there are no participating health plans with QHPs offered
On the face of this narrative, yes it makes sense. This market instability is unacceptable. No one can celebrate a law who’s principal intent is to expand coverage can applaud the absence of health plan participation at the state or county level.
But let’s peel back the curtain and look at the reasons for this ‘instability‘ claim. From day one of the Obama Administration, the GOP agenda was to make him a ‘one term President‘.
On the ACA given it’s passage was a straight line party vote with no support from GOP even though the health reform consideration process was an open and lengthy affair, Senator McConnell et al’s agenda was to remain the ‘party of no‘ and criticize the very model of health reform they had not long ago proffered as a public/private solution, See: ‘GOP ACA Myths‘ where I’ve posted links to credible voices and JD Kleinke’s classic: ‘Why There Is No Obamacare Replacement — In One Picture‘.
The bottomline is any ‘fails’ or under performance of the ACA whether enrollment projections, premium sticker shock, exchange exits or regulatory burdens have been engineered by a relentless series of sabotage efforts from defunding risk corridors, to current (see: This Blame Game Driving Up Health Insurance Costs) threats to not fund the subsidies that make QHP listed plans ‘affordable‘. And let’s not forget the big SCOTUS decision on Medicaid expansion which gave Red State Governors the ‘option’ whether to expand coverage for their citizens.
So the ‘who knew healthcare was so complex’ remark offered by POTUS earlier this year was pure BS. I buy his ignorance of health policy and the complexity inherent in a cottage industry with a $3+ trillion spend, but what about those GOP ‘health wonks’ engaged in this process – from the ‘Senate Quackers’ (my term), i.e., Tom Coburn and John Barrasso – both politicians playing the doc card during ACA markup in 2009, or even worse one half of the GOP ‘young guns’ now Speaker Ryan who’s a budget [and by declaration health] wonk. What’s their excuse for this ‘surprisingly epic fail’?
This is a HUGE squander of the public trust! And contrary to POTUS assertions, the GOP now has complete ownership of the chaos they’ve stoked from the beginning to this gross mis-management of the legislative process. It’s laughable that GOP are trying to pin this one on the Democratic party.
My god, wake up GOP. You ‘own’ healthcare. Fix the ACA.
Since ACOs arrived in 2012 courtesy of the Section 3022: Medicare shared savings program, under Title III, Subtitle A, Part 3 of the Affordable Care Act (ACA) as the ‘new, new thing’ layered into a complex healthcare ecosystem peppered with more or less successful public/private efforts to restrain healthcare inflation, promote greater patient/member access, provide seamless coordinated care at lower per capita costs with better documented quality (the triple aim), ACOs have booked modest, variable but increasingly scalable impact via sponsored hosts from institutional health systems to physician driven enterprises.
A Brief Timeline
In 1973 President Richard Nixon signed into law the ‘HMO Act‘ officially launching ‘managed care‘ principally via closed ‘staff‘ and ‘group‘ model HMOs catering to niche (vs. ‘mainstream’) segments of key industry stakeholders, i.e., members (patients), employers, participating physicians and hospitals.
In the early to mid 80’s we witnessed the accelerated migration from narrow market penetration to mainstream medicine validation of the HMO model via the emergence of network models typically enabled by then emerging ‘Independent Practice Associations’ (IPAs).
Most IPAs emerged as a loose confederation of participating physicians as many physicians engaged out of a sense of curiosity or defensive hedging to not lose patients. First generation IPA’s featured at best tepid economic bonds, thus alignment of member physicians with the entity ‘leadership‘ (i.e., the Management Services Organization) goals were often ‘incidental considerations’ to many participating physicians. There just wasn’t enough ‘skin in the game‘ or economic integration, i.e., losing a withhold against a fee-for-service schedule just didn’t make that much of a difference from a total compensation point of view.
In the mid 80s principally in California Preferred Provider Organizations (PPOs) emerged and launched the era of discounted fee-for-services contracting for hospital, physician and ancillary services. PPOs were an HMO-lite version as members/beneficiaries voted with their feet within the network based on ‘in network’ benefit plan incentives vs. the closed loop (gatekeeper) HMO model.
In the 90s as mainstream initiatives continued to evolve and mature we witnessed the emergence of Physician/Hospital Organizations (PHOs) more often than not a joint venture between a host hospital (or parent health system) and a member physician organization (typically one or more IPAs or multi-specialty medical groups). PHOs were contracting vehicles and typically supported by an affiliate or owned MSO. Few PHOs entered into full risk arrangements with payors.
For prior comment and context on the evolving market, check out ‘Hey, Remember IPAs, PPOs and TPAs?’
Enter the ACO
While an ‘alphabet soup‘ of healthcare cost containment and quality improvement acronyms enshrined themselves into US healthcare delivery and financing lexicon (HMO, IPA, PPO, PHO, MSO, EPO, DPA, OWAs [other weird arrangements]), healthcare consumption of GDP continued it’s relentless upward growth – though somewhat moderated post passage of ACA.
In 2012 27 ACOs officially launched under the terms and provisions of the Medicare Shared Savings Program (MSSP) via a cohort sourced from 18 states serving an estimated 375,000 beneficiaries. Approximately half of the participating ACOs were physician-led, per the Center for Medicare and Medicaid Innovation (CMMI) – the administering agency.
Amidst ‘mixed results‘ considerable provider input to CMMI via open door forums and NPRM comments the ensuing years witnessed many tweaks to the rules associated with both the MSSP and Pioneer programs. In January of 2015 then Secretary of Health and Human Services Sylvia Burwell set goals for migration of payments from volume to valued based arrangements, see: ‘HHS Sets Specific Targets and Timelines for Alternative Payment Models and Value-Based Payment‘:
By the end of 2016, HHS plans to make 30 percent of FFS payments through APMs, such as accountable care organizations (ACOs) and bundled payments, and tie 85 percent of all FFS payments to quality or value. By the end of 2018, HHS intends to pay 50 percent of FFS payments through APMs, and tie 90 percent of FFS payments to quality or value.
This represents the first time in my 30+ years in healthcare delivery and financing innovation space that the Federal government has explicitly benchmarked industry migration away from its prevailing fee for services DNA.
While many pronounced ACOs as ‘DOA’ (dead on arrival) for many reasons, truth be told they’ve found their way into the managed competition ecosystem and are not going away anytime soon. In fact as is the case with most innovation, the ACO formula has been tweaked both in terms of its Government DNA (MSSP, Pioneer models, etc), and it’s private pay or commercial derivatives.
Meet the ‘Next Generation ACO Model’
The de facto amalgam of much of the lessons learned and serial tweaks imposed since the first class of ACOs launched in 2012 can be found in the Next Generation ACO Model, see: ‘The Next Generation ACO: Accelerating the Transformation from Volume to Value‘.
Per CMS, the model is defined as:
The Next Generation ACO Model is an initiative for ACOs that are experienced in coordinating care for populations of patients. It will allow these provider groups to assume higher levels of financial risk and reward than are available under the current Pioneer Model and Shared Savings Program (MSSP). The goal of the Model is to test whether strong financial incentives for ACOs, coupled with tools to support better patient engagement and care management, can improve health outcomes and lower expenditures for Original Medicare fee-for-service (FFS) beneficiaries.
Included in the Next Generation ACO Model are strong patient protections to ensure that patients have access to and receive high-quality care. Like other Medicare ACO initiatives, this Model will be evaluated on its ability to deliver better care for individuals, better health for populations, and lower growth in expenditures. This is in accordance with the Department of Health and Human Services’ “Better, Smarter, Healthier” approach to improving our nation’s health care and setting clear, measurable goals and a timeline to move the Medicare program — and the health care system at large — toward paying providers based on the quality rather than the quantity of care they provide to patients. In addition, CMS will publicly report the performance of the Next Generation Pioneer ACOs on quality metrics, including patient experience ratings, on its website.
A thorough application vetting process by CMS will assure participating ACOs admitted to the ‘NextGen’ cohort will present with the track record and capabilities to assume and manage the risk inherent in the model. Rather than bolt a new model on a legacy fee-for-services platform, CMS is fueling the necessary innovation to achieve the triple aim via a network of risk savvy ACOs.
Next Generations ACOs will deploy three (3) powerful ‘benefit enhancement‘ tools as they re-engineer clinical workflows and the prudent utilization of acute and sub-acute healthcare resources. This includes:
- Telehealth Expansion Waiver
- Post-Discharge Home Visit Waiver, and
- Three-Day Skilled Nursing Facility Waiver
First up as we cycle through and profile best in class Next Generation ACOs is National ACO, led by industry pioneers and co-founders Andre Berger, MD, CEO and Alex Foxman, MD, FACP, President and Chief Medical Officer who serve as co-hosts of this series.
The series launches May 23, 2017 from 5PM – 5:30 PM Pacific/8PM – 8:30 PM Eastern. You can listen both live or on demand via This Week in Accountable Care.
We’ll discuss the model, their backgrounds and history in managed care and why they were drawn to form National ACO. We’ll close with comments from Alex Fair, CEO of the equity crowd funding platform Medstartr who will detail the recent listing of National ACO.
*Editor’s Note: This post including This Week in Accountable Care broadcasts, periodic tweetchats via #ACOchat and blog posts in this series) are sponsored by National ACO, a Next Generation ACO. For more information on National ACO, click here.
In our healthcare innovation economy from the private sector to material modifications of public programs including Medicare and Medicaid there is a massive effort to identify and enable sustainable delivery and financing schema to stem the treasury bleeding and inch however incrementally towards ‘universal coverage’.
Ideological talking points opposing ‘Obamacare‘ aka the Affordable Care Act (ACA) notwithstanding, there are tangible efforts to move the needle in play while the uncertainty of a successor to the ACA remains largely ‘on the come’.
Continuing on this post ACA momentum, the Centers for Medicare and Medicaid recently weighed in on the ‘Quality Payment Program‘. Acting Administrator Andy Slavitt provides introductory remarks and is followed by his CMS colleagues who provide deeper dives into the QPPs two track choices: the Merit Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APM).
To listen to the complete call we’re rebroadcasting it on ‘This Week in Health Innovation.‘ It is archived for on demand replay.
Original link to CMS QPP is here.
You’ve no doubt heard the expression: ‘a picture is worth a thousand words‘.
Well courtesy of Oliver Wyman Health we have an infographic that segments key provisions of ‘TrumpCare’s‘ impact on providers. For original graphic, click here, and timely commentary, see: ‘Special Election Coverage: What Now? The Impact of a Trump Presidency‘ via Partner Sam Glick.
Oliver Wyman breaks down the identifiable components of TrumpCare’s impact on providers as follows:
So much ‘meat’ remains to be put on the bone. Assuming anything whether ‘substantiated’ by previous campaign rhetoric or more recent ‘indicia‘ of what will emerge post ‘repeal and replace‘ or now ‘amend’ intentions relative to the ACA (see: ‘As the TrumpCare Pivots Begins‘) is without a doubt ‘faith based‘ reliance on what remains essentially an aggregate ‘hologram‘ of President-Elect Trump’s health reform agenda.
Just when we thought it was safe to get back in the ‘white water of health reform‘ with needed fixes to this arguably complex and ambitious Act, surprise!
Against all odds and the best and brightest minds in the polling community welcome President-Elect Donald Trump and his litany of public statements regarding the intent to ‘repeal and replace’ the Affordable Care Act ‘day one‘.
There is so much to this story that it’s difficult to fix a single point of entry, so we’ve sourced just a few of his public statements to frame the discussion which we’ll launch here but dive further into at This Week in Health Innovation and PopHealth Week with my colleagues Fred Goldstein and Douglas Goldstein.
Last week the Wall Street Journal posted a piece which began what some now expect to be the inevitable revisionist walk-back on the range and depth of what is realistically possible for the categorical ‘repeal and replace‘ rhetoric of this ‘holographic‘ candidate, now President-Elect Trump. Trump has been rather clear that the ACA aka ‘Obamacare’ is a ‘disaster‘ and must be thrown out and replaced with some ‘beautiful‘, ‘bigly‘ or who knows what else occurs to him as a politically feasible replacement alternative?
Some of my colleagues in the health policy and health-wonk space who’ve inexplicably (in my view, though see: ‘Dear Mr. President-Elect, about that Ryan Plan Thing‘) hitched to the TrumpTrain and it’s Rorschach projection of what is to become ‘TrumpCare‘ have stunned me by proffering seemingly apologist precedent for his now revisionist tune:
Just to make sure you have the facts.. 🙂 He said in early primaries and consistently after that that preexisting and all that stays in.
This was in response to the following tweet given the WSJ piece:
Yet here’s just a sampling of public statements made during his campaign:
This portion of Trump’s health reform agenda is so target rich and ‘on the come‘ while campaign rhetoric meets the real world of policy and politics, so we intend devote a fair amount of coverage and commentary to TrumpCare’s emerging policy indicia.
Meanwhile, here is the vision posited to the people and the Congress of the President Elect’s health reform (similar as ‘guidance‘ offered though materially at variance with Obama’s ‘8 Principles’) submitted to Congress as parameters for the debates and negotiations eventually leading to the passage of ACA:
Some related references here:
We do in fact live in interesting times!