Accountable Care, ACO, Affordable Care Act, health reform

Founder and CEO of ACO Management Company Weighs in on Regulatory Uncertainty

by Gregg A. Masters, MPH

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.

Farzad Mostashari MD CEO Aledade ACO

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. 

Farzad Mostashari @Farzad_MD

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.

fiercehealthcare.com/payer/medicare…

Farzad Mostashari @Farzad_MD

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.

Farzad Mostashari @Farzad_MD

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

Farzad Mostashari @Farzad_MD

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.

Farzad Mostashari @Farzad_MD

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.

Farzad Mostashari @Farzad_MD

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!

 

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Accountable Care, ACO, Triple Aim

ACOs in the Medicare Shared Savings Program (MSSP): Is There a Fix?

by Gregg A. Masters, MPH

The Center for Healthcare Quality and Payment Reform just released ‘How to Fix the Medicare Shared Savings Program‘ with lead author and long term managed health care industry veteran Harold D. Miller, its President and CEO. 

Some six (6) years into the Affordable Care Act (ACA) provisions specific to Accountable Care Organizations (ACOs) the results remain mixed at best, and like the serial tweaks made to the Medicare Advantage Program, now covering some 30% of Medicare beneficiaries, the underlying ACO structural characteristics and enabling health policy regulations remain ‘on the come‘ for this still nascent and evolving delivery system model.

For the many critics of ACOs as a form of an ‘HMO lite‘ in the fee-for-services Medicare market, with none of the channeling characteristics commonly associated with HMOs, this comes as no surprise.

In this just released report, Harold Miller weighs in on the fix he sees essential for the program to achieve it’s cost containment and quality improvement objectives.  The executive summary is posted below and the full report is available here.

Executive summary:

Rather than generating savings as expected, the Medicare Shared Savings Program (MSSP) has created losses for the Medicare program for four years in a row.

Calculations by the Centers for Medicare and Medicaid Services (CMS) appear to show that ACOs with downside risk produce higher savings than the “upside-only” ACOs. However, Medicare actually spends more per beneficiary in the downside risk ACOs than in other ACOs, with no difference in quality. Moreover, ACOs that have moved to the downside risk tracks have saved less after doing so.

The risk adjustment and benchmarking formulas used by CMS can penalize ACOs that serve higher-need patients and patients living in rural areas. The greater savings attributed to downside risk ACOs may have more to do with differences in the types of patients they see than differences in the way they deliver care.

Concerns about the problems with the risk adjustment and benchmarking methodologies in the MSSP have made many ACOs unwilling to enter the downside risk tracks. Requiring all ACOs to move to downside risk could force successful ACOs to leave the program, thereby reducing Medicare savings and harming the quality of care for millions of beneficiaries.

There are other options for modifying the Medicare Shared Savings Program in order to increase Medicare savings, including dropping ACOs from the program if they fail to achieve savings after two consecutive years, reducing shared savings payments for ACOs that incur losses before achieving savings, reducing the shared savings rate below 50% for Track 1 ACOs, and/or enabling ACOs to take accountability for the specific types of services they can control rather than placing them at risk for
total Medicare spending.

Neither shared savings nor shared risk payment models solve the fundamental problems in the fee-for-service payment system. As a result, it is unlikely the MSSP will ever result in significant savings or improvements in quality, and it has the potential to harm patients by rewarding providers that withhold necessary services.

Instead of continuing to modify the Medicare Shared Savings Program, CMS should focus on implementing Patient-Centered Alternative Payment Models that provide the resources physicians, hospitals, and other providers need to successfully address their patients’ healthcare needs while holding the providers accountable for those aspects of spending and quality they can control.

Twitter Dialogue on ACO Results Reported

Today on twitter there was a representative exchange from both sides of the ACO narrative which I’m posting below for context:

MANas8U's avatar

True! Yet innovation is not cheap + anything even moderately at scale in Medicare/Medicaid is definitely not cheap. Questions while innovating: What did we learn? How can we inform our future efforts? @policywonk1

danmunro's avatar

I would argue that the evidence is already in b/c the trajectory we’re on is easy to see – and forecast. Just labeling newer efforts of ‘cost containment’ as ‘innovation’ is like rearranging (in this case expensive) deck chairs.

danmunro's avatar

But that may be the same hymnal in title only: HC Reformation I don’t think #FFS is “an addiction” that needs #ACO or #VBP rehab and the evidence that #FFS works reasonably well around the world is compelling. We don’t need single-payer, but we absolutely need single-pricing.

A Sampling of ACO Leadership on the Center for Healthcare Quality and Payment Reform Report and Associated Remedies

Our Nation’s move from volume to value based care will not occur in one day. Transformation of our complex, misaligned and disjointed healthcare system will take the hard/smart work, dedication, risk and financial support from key stakeholders, including the largest being CMS. Transition to risk based/value based care is not an option, it is a necessity not only to save but successfully advance the US Health Care system. It is easier to point out problems, than to roll up our collective sleeves and develop innovative and outside the box solutions.  – Alex Foxman, MD, FACP, CMO, President and Co-Founder National ACO, LLC

The state of Florida is a great example of ACOs having success.  I believe this is true because we already have a vibrant managed care market.  Medicare Advantage makes a lot of people money but has not proved it has saved any.  It has only served to risk adjust a population for higher revenues.  ACOs, as originally designed, may only be ‘transitional’ but they are an important step toward shifting from volume to value payment models. We should expect the models will continue to evolve.  This shift is a jog not a sprint. The goal and focus should be on the “shift” not which model and flavor is the stepping stone along the way. – Nicole Bradberry, CEO and Chair of Board, Florida Association of ACOs 

ACOs in Florida reduced expense by $365,809,069, earned shared savings payments of $178,447,886 with a net benefit to the Medicare trust fund of $187,361,183. MSSP is working in Florida! We’re concerned that the success of the MSSP is being evaluated based aggregate ACO performance which includes ACOs who are not putting forth adequate effort. I know of at least 7 ACOs that have 2 or less employees. That’s not enough effort to make ANY business model work! Unfortunately their results are tabulated with others and cause the program to be inaccurately evaluated. We look forward to the required transition to downside risk as it will require those without much commitment to drop out. If you drop the minimum effort ACOs, we expect the aggregate ACO results will look different. This is PY 2016 data… –  David Klebonis, Chief Operating Officer, Palm Beach Accountable Care Organization & Chief Operating Officer, South Florida Accountable Care Organization 

One definition of literal fantasy requires only that we accept a single non-reality, after which the rest of the story becomes quite plausible. If that be the case, Mr. Miller has written a Best Seller. His entire analysis assumes that the CMS “Shared Savings” formulas reflect reality, when those of us that have really crunched the numbers know this is far from the truth.

Intentionally or not, CMS has built significant savings for the Trust Fund into the benchmark methodologies for both MSSP and NextGen. These range from the actuarial fallacies inherent in continuous attribution, successful ACO market share effects on the “Benchmark”, National Efficiency ratios that divert Benchmark dollars from high attribution areas to low attribution areas, risk score caps, automatic “discounts” and much, much more.

Still, it seems that our Florida ACOs consistently overcome the increasing headwinds and succeed. Additionally, CMS recognizes the problems in their own Benchmarking models and has tweaked these year after year, including the latest Proposed Rule submitted by MSSP to OMB earlier this month. I fear Mr. Miller is whistling past the graveyard on this one.

For a glimpse into a few of the methodology problems, see ‘Regional Benchmarking or Regional Bonus? Sustainability in the Medicare Shared Savings Program‘. – Richard J. Lucibella, CEO, Accountable Care Options

 

A Continued Search for Answers and Business Models

Further context sourced from the Florida Association of ACOs annual conference last year was provided by Aledade co-founder and CEO and former National Coordinator for Health Information Technology at the Office of the National Coordinator Farzad Mostashari, MD here.

Weigh In

So what do you think? Please offer your thoughts in the comments section. This is a dialogue well worth a broader exchange as our industry evolves perhaps even ‘pivots’ from it’s near term PCMH or ACO roots to a the valued based healthcare model – one that many refer to as a ‘Rorschach test’ of sorts – where any projection of what constitutes a value based model will do.
Please feel free to post any resources that support your take and we’ll happily include via our social reach. If any of you are inspired to author a guest post with references of citations, we’re happy to include at ACO Watch.

 

Accountable Care, ACO, Affordable Care Act

Center for Medicare and Medicaid Services Releases Accountable Care Organization Performance Results

by Gregg A. Masters, MPH

Friday, October 27th, the Center for Medicare and Medicaid Services (CMS) released details for participating Accountable Care Organizations (ACOs) in the Medicare Shared Savings Program (MSSP) for the 2016 performance year.  For reporting ACO results view the entire report here.

The National Association of ACOs (NAACOs) weighed in below:

The new results demonstrate the value of a premier Medicare alternative payment model and include a higher rate (56 percent)* of MSSP ACOs generating savings than ever before and an almost equal proportion as last year of ACOs that earned shared savings (31 percent).

This public update follows previously posted results for Pioneer ACOs, the Next Generation ACO cohort and the Comprehensive End Stage Renal Disease ACO (ESRD) care model here.

In table form, the results are summarized below:

All in, participating ACOs generated $843 million in gross program savings with a modest net savings of $78.6 million for Medicare in 2016, in addition to material gains in quality scores for aligned ACO Medicare beneficiaries.

While Clif Gaus, NAACOS CEO notes:

These results show the growing success of ACOs, which is a positive trend that should not be ignored. A lot has been accomplished in a relatively short amount of time, and ACOs are on the front line of redesigning healthcare delivery. This is a moment to celebrate them and their hard work.

The ACO ‘Jury’ Is Still Is Out

Given the range of models, risk assumed or gain sharing distributed operating results in a program that some still see as fundamentally ill equipped in a predominant fee-for-services market to materially change physician and beneficiary behavior – and thus enable the elusive ‘triple aim‘ – many in the health policy area including select ACO operators remain convinced to maximize impact the ACO model will ultimately morph into the more robust Medicare Advantage operating platform.

Perhaps the ‘stealth play’ in the mix is the potential upside of Next Generation ACOs to fully leverage their competitive advantages (3 day SNF waiver, telehealth visits, relaxed supervision requirements for post hospital discharge visits and the move to all inclusive population based payments) can up-level both their game AND improve outcomes at lower per capita costs?

On the next episode of This Week in Accountable Care, our very special guest is former Acting Administrator of CMS Andy Slavitt, now Senior Advisor to the Bipartisan Policy Center. Andy was initially part of the ‘fix it dream team‘ that righted the failed launch of Healthcare.Gov, and then presided over the administration of the Affordable Care Act.

Andy is rather familiar with the original intent of the ACA, its many ‘working parts’ and the bumps in the road to perfect the law via provider input, updated rule making and policy refinements.

We’ll get Andy’s take on a range of issues from the political environment to conflicting health policy guidance including broad brush advice to ACO operators.

Join National ACO co-founders Andre Berger, MD and Alex Foxman, MD as we engage this visionary and accomplished entrepreneur turned public service official in critical dialogue impacting the transformation of our industry from its fee-for-services roots to a new model based on a value and patient centricity.

 

Accountable Care, ACO, Affordable Care Act, Triple Aim

ACOs Fudging the Numbers?

by Gregg A. Masters, MPH

I came across this piece on the Healthcare Blog penned by Kip Sullivan, Esq, critiquing this article posted in Health Affairs last May ‘Bending The Spending Curve By Altering Care Delivery Patterns: The Role Of Care Management Within A Pioneer ACO‘. Sullivan raises valid points as the the legitimacy of claiming or inferring statistically insignificant results as a meaningful contribution of the subject ACO (a Partners Health sponsored venture) to ‘bending the cost curve’.

Sullivan un-bundles his argument effectively and raises issues for the industry writ large – including participating ACOs, their sponsors, the regulatory crew at both CMS and CMMI – and even the health policy press covering the sector.

I post the first few paragraphs of the piece below, for full reference the entire article on the Healthcare Blog is accessible via On the Ethics of Accountable Care Research‘.

  • Is it ethical for health policy researchers to claim that a Medicare ACO reduced “spending” by 2 percent if the reduction was not statistically significant?
  • Is it ethical for them to do so if they made no effort to measure the cost to the ACO of generating the alleged 2 percent savings nor the cost to Medicare of giving half the savings to the ACO?
  • Does it matter that the researchers work for the flagship hospital within the ACO that was the subject of their study?
  • Does it matter that the ACO and the flagship hospital are part of a huge hospital-clinic chain that claims its numerous acquisitions over the last quarter-century constitute not mere empire-building but rather “clinical integration” that will lower costs, and the paper lends credence to that argument? 
  • Is it ethical for editors to publish such a paper? Is it ethical to do so with a title on the cover that shouts, “How one ACO bent the cost curve”?

These questions were raised by the publication of a paper  by John Hsu et al. about the Pioneer ACO run by Partners HealthCare System, a large Boston hospital-clinic chain, in the May 2017 edition of Health Affairs. Of the eight authors of the paper, all but two teach at Harvard Medical School and all but two are employed by Massachusetts General Hospital (MGH), Partners’ flagship hospital and Harvard’s largest teaching hospital. [1]

Partners has been on a buying and ….

Comment

As someone who’s been in this dance since the mid 70s (PSROs, HSAs, HMOs, IPAs, PPOs, EPOs & all derivative plays) launched into Medicare risk via TEFRA (the Tax Equity and Fiscal Accountability Act) which introduced us to ‘Medicare Choice’ the for-runner of Medicare Advantage, I can say Sullivan’s critique of fully ‘burdening‘ ALL transformational efforts is rarely – if ever – factored into the volume to value pivot ‘investment calculus‘ of the effects of the intervention (in this case a Pioneer ACO) on the national spend.

It should be noted, the entire managed care industry can be assessed a gigantic collective FAIL for that matter as well. Since managed care penetrated ‘mainstream medicine‘ principally via extension of the HMO model typically on an IPA (independent practice association) chassis (vs. group or staff models) with the exception of a brief period in the 90s premiums continue their relentless upward march; while most payors continue to write commercial business only via an enterprise and industry wide cost shifting (risk transfer) charade. The tacit admission that there is no there there in the prevailing health insurance industry zeitgeist. They’ve proven they can NOT manage clinical risk, period.

So Kip, you might want to go a little lighter on those on the front lines trying to tame the ‘rapacious appetite’ of our ‘healthcare borg‘!

 

 

Accountable Care, ACO, Affordable Care Act

The NextGen ACO: Another Round Opens

by Gregg A. Masters, MPH

The Centers for Medicare and Medicaid Innovation has announced the results of its ‘continuous learning‘ commitment model wherein ‘field reports‘ including provider comments and open door inputs are materially incorporated into tweaks of the Medicare Shared Savings Program (MSSP) as risk is progressively adopted by participating ACOs. This ‘new round’ iteration no doubt includes ‘lessons learned‘ from the Pioneer ACO Program including the many ‘exits’ and risk downgrades opted to date.

In summary, this round is:

‘..one that sets predictable financial targets, enables providers and beneficiaries greater opportunities to coordinate care, and aims to attain the highest quality standards of care.’

screen-shot-2016-12-15-at-9-48-25-am
screen-shot-2016-12-15-at-9-48-47-am

screen-shot-2016-12-15-at-9-49-21-am

For complete information, see: ‘Next Generation ACO Model | Center for Medicare & Medicaid Innovation‘.

 

 

Accountable Care, Affordable Care Act, health reform

TrumpCare: What We ‘Know’?

by Gregg A. Masters, MPH

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.
TrumpCare Impact on providers

Oliver Wyman breaks down the identifiable components of TrumpCare’s impact on providers as follows:

TrumpCare screen-shot-2016-11-15-at-10-06-48-am screen-shot-2016-11-15-at-10-07-00-am

 

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.

Stay tuned!

 

Accountable Care, Affordable Care Act, health reform

As the TrumpCare Pivots Begins

by Gregg A. Masters, MPH

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 Actday 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:

screen-shot-2016-11-14-at-9-46-31-am

Yet here’s just a sampling of public statements made during his campaign:

trumpcare1

trumpcare7

trumpcare12 trumpcare10 trumpcare8 trumpcare7 trumpcare6 trumpcare5 trumpcare4 trumpcare3 trumpcare2

trumpcare8

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:

TrumpCare

Some related references here:

http://www.sciencemag.org/news/2016/11/here-s-some-advice-you-president-trump-scientists

http://www.politico.com/story/2009/02/obama-care-101-the-presidents-8-principles-019362

https://www.sciencebasedmedicine.org/medical-science-policy-in-the-u-s-under-donald-trump/

We do in fact live in interesting times!