Accountable Care, ACO, Affordable Care Act

MACRA, MIPS and APMs: A Report from CAPG

by Gregg A. Masters, MPH

So everyone is talking about value based healthcare. No longer is ‘business as usual‘ even an option on the table as the volume driven FFS zeitgeist continues to lose supporters in health policy circles while a growing body of clinical initiatives from ACOs to a range of variably structured and differentially market positioned risk bearing organizations (RBOs) model the new paradigm.CAPG_Guide to APMs

For some this value based healthcare mantra is code-speak for the associated narrative if not mandate to reflect all payment or delivery system model entries that shift clinical risk to providers whether ‘institutional‘, i.e., hospitals and/or their parent health systems (including IDNs), or ‘professional‘, i.e., physician networks, enterprises, medical groups or their managing agents (MSOs). This pool of value based participants includes a range of ACOs whether participating in the Medicare (MSSP or other options) program or their commercial derivatives as negotiated by many of the national or regional health insurance companies; not to mention ‘OWAs’ (other weird arrangements) that arguably incorporate one or more strategies to play and thrive under a range of risk based incentives.

CAPG_Guide to APMs_matrix

Contributing clarity to an arguably non-homogeneous market including performance results to date via provider entity type use cases is CAPG (fka as the California Association of Physician Groups) who recently published ‘CAPG’s Guide to Alternative Payment Models: Case Studies of Risk-Based Coordinated Care‘. 

This is a timely and resource rich report sourced from an eclectic pool of risk savvy industry players (CAPG members) that CAPG Executives Don Crane, President and CEO, and Mara McDermott, Vice President of Federal Affairs, introduce as follows:

You’ll … learn where each model is successful and strong, and where each has room for improvement. Key areas where CAPG members are demonstrating success in APMs include:

• Improving the quality and efficiency of care for patients. These APMs align physician payment to the achievement of performance objectives.

• Encouraging team-based care and a commitment to primary care.

• Innovating to better meet the needs of patients, particularly those with chronic conditions.

In addition to the significant progress our members are making in improving patient care and innovation, several themes have emerged where there is room for improvement:

• Improving data sharing with payers to continue to drive care improvements.

• Engaging patients in new payment approaches, particularly in accountable care organizations (ACOs).

• Aligning quality measures across programs. This will play an important role in reducing the burden on physician practices and getting actionable information to consumers.
As physicians across the nation embark on this journey toward risk-bearing arrangements, we hope you find this paper a practical, helpful, and invaluable guide. 

 

Most of you will connect and more or less identify with the ‘it takes a village‘ [to raise a child] admonition popularized by the presumptive Democratic Nominee for President, Hillary Clinton. In the grand transformation of a change resistant and to a very large degree legacy inertia driven healthcare financing and delivery ecosystem, this village idea may just be a gross understatement. Rather, I think the then Acting Administrator of CMS Don Berwick got it right scaling the true nature of the challenge before healthcare leadership, which is to steward the market mandated transformation via an ‘all hands on deck, full court press‘ invitation to make this transformation even remotely possible. In other words, this will take much more than just a ‘village‘.

Major props to CAPG for an important body of work on this nascent and ‘learning as we go‘ industry.

 

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Accountable Care, ACO, Affordable Care Act, MSSP

Final Medicare Shared Savings Program Rule (CMS-1644-F)

by Gregg A. Masters, MPH

Creating consistent high quality original content is hard. At ACO Watch, we’re not in the business of breaking news or high frequency posts to drive eyeballs and traffic to this blog so ‘the numbers’ that might attract advertising or sponsorship (there aren’t any). Instead we (mostly me) watch the developments in the sector and offer newsworthy items now and then with some commentary which usually tethers to institutional memory (often failure, some successes) of having been in this dance for a while.cms final rule MSSP

So here’s the latest from CMS on the proposed final rule for ACOs participating in the Medicare Shared Savings Program, see published rule here.

I remember back in the day when CMS was known as HCFA (the Health Care Financing Administration) and inside the Baltimore HHS complex, there dwelled an office with the name ‘Alternative Delivery Systems’ (ADS). This was the locus of staff (very modest at that time) tasked to monitor and track what was then limited to HMOs and the newly minted though ‘lite version’ dubbed PPOs.

Fast forward some 45+ years and those ‘alternative entities’ have become mainstream so to speak. Literally all benefit plans written today are contractually delivered via participating providers (IPAs, PHOs, IDNs, health systems, alliances, networks, direct or more recently ACOs) are some form of ‘managed care’ unless those providers have opted out of Medicare, Medicaid and commercial insurance in favor of Direct Practice or worse ‘Concierge Medicine’.

Since the Secretary of Health and Human Services has recently set a goal to have Medicare move away from its traditional reliance of unbridled fee-for-services medicine to a range of what CMS has or will define as ‘value based care‘ arrangements – everything from bundled payments, to gain sharing, to partial or global risk assumption by providers (hospitals, health systems, IPAs or ACOs (the next generation) much attention has focused on the right combination of incentives, infrastructure and regulatory context to move this historically change resistant healthcare delivery ecosystem into the brave new world of value vs. volume.

This is the latest effort by CMS to tweak the ACOs regs in order to meet some of the persistent objections to the program while scalably incentivizing the essential journey to risk assumption by providers is noted as:

The policies adopted in this final rule are designed to strengthen incentives in order to continue broad-based program participation and improve program function and transparency.

While the broader context is summarized as:

On June 6, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a final rule to incorporate regional fee-for-service (FFS) expenditures into the methodology for establishing, adjusting, and updating the benchmarks of Accountable Care Organizations (ACOs) that continue their participation in the Medicare Shared Savings Program (Shared Savings Program) after an initial three-year agreement period. This final rule also adds a participation option to encourage ACOs to transition to performance-based risk arrangements and provides greater administrative finality around the program’s financial calculations. CMS is making these modifications to strengthen incentives under the program after considering comments received on issues specified in the 2016 notice of proposed rulemaking. 

There is more to the story, and the referenced PR is here.

 

 

Accountable Care, Affordable Care Act, Triple Aim

Hey, Remember IPAs, PPOs and TPAs?

by Gregg A. Masters, MPHAAPAN 2016 Forum

In a last man standing of sorts in what some may call the legacy and aging infrastructure of the ‘vote with your feet‘ PPO industry including it’s allies in the TPA (Third Party Administrator) space, the American Association of Payors, Administrators and Networks (AAPAN) is holding its 2016 Annual Forum in my former hometown of Dana Point, California at the Ritz Carlton, Laguna Nigel.

The mission of American Association of Payors, Administrators and Networks (AAPAN) notes it provides:

….the platform for the unification of payers, administrators and networks and the ability for a stronger collective public policy voice to enhance the position of each stakeholder as essential to the future of affordable healthcare delivery options centered on patient choice.

According to its subsidiary the American Association of Preferred Provider Organizations (AAPPO) the ‘PPO chassis’ accounts for:

An estimated 200 million Americans, or about 81 percent of all Americans with health care coverage (excluding those receiving military health care), receive their health care services through a PPO delivery system.

A history of managed care As a ‘collaborative association’ on behalf of the PPO industry initially positioned as a complementary (if not an HMO-lite) alternative to the more aggressive gatekeeper HMO option (see history of managed care era in graphic), AAPAN has a track record of success from advocacy, to thought leadership and operating best practices and solutions.

The Association aligns two potentially silo-ed (though synergistic) interests: the American Association of PPOs (AAPPO), the Third Party Administrators Association of America (TPAAA). For an issue brief on valued based healthcare and the need for network standards, see: The Need to Standardize Network Value-Based Purchasing Requirements.

So one might say, though a larger share of the employer based insurance market remains in a PPO type (vs. HMO) benefit plan design their role and industry leadership visibility may have been somewhat muted (if not, absent from the health reform narrative) since the rollout of the Affordable Care Act (ACA) and it’s emphasis on Accountable Care Organizations (ACOs) dominated the reform narrative.

AAPAN intends to raise this profile and remind many in the space that PPOs, TPAs and even IPAs (Independent Practice Associations) have a material and meaningful role to play in enabling the triple aim even if their initiatives aren’t tagged ACOs per se.

The 2016 Forum hashtag is #AAPAN16, and the digital dashboard is here. Do follow the tweetstream for thought leadership insights from key industry executives, entrepreneurs and change agents. See keynotes and sessions here, including Health Innovation Media co-host, Douglas Goldstein aka @eFuturist.

The program schedule is here.

 

Accountable Care, Affordable Care Act, health insurance reform

12 Steps to the Triple Aim or Value Based Healthcare

by Gregg A. Masters, MPH

It has been challenging at times being in the ‘innovation conversation’ dating back to the 70s (who remembers ‘WIN’ [whip inflation now], PSROs or even HSAs (no, not the WIN \ Whip Inflation Nowprivatization funding mechanism, but the CON overlords) watching what get’s reported by industry press or online media as ‘innovation‘ or ‘bold new thinking‘ amidst a ‘cottage industry’s’ 3x trillion spend rate – including it’s culpable supply chain and many vendors (some may even say ‘pigs’) at the trough.

As indicia of the impending collapse of our aging house of cards healthcare delivery and financing industry (continued burnout rates driving physician exits to direct practice or concierge medicine, un-ending and nauseating opposition to the ACA, mega and no so mega hospital mergers, associated practice acquisitions and health plan consolidation, not to mention the codification of the cost shift charade via the lower metals designations of the ACA and including armies of dissatisfied patients suffering in a provider centric culture) continues to accumulate, it affirms what Esther Dyson once presciently characterized as the ‘calcified hairball‘ given it’s ‘resistance is futile’ [to change] nature.

Healthcare Inflation

Recent healthcare inflation moderation trends notwithstanding (see: ‘2014 National Health Spending; The Great Moderation Likely Not Over‘ by healthcare futurist Jeff Goldsmith) whether a function of ACA implementation in part of as a whole, the industry has essentially and collectively failed to deliver on the principles of the triple aim – which existed in spirit considerably before it’s labeling by the Institute for Healthcare Improvement (IHI). Providers continue to maximize their profits or ‘excess revenues over expenses’ for the ‘non-profit’ [aka tax exempt’ sector] often at the expense of community benefit.

Perhaps no other chart series in line item detail captures and evidences this slow burn of fail as the progressive and relentless growth of one man’s healthcare premiums in California. Take note of the persistent [cost] shift from the payer (health plan) to the patient or beneficiary.  If this is the best we can do via ‘wholesale purchasers’ (market savvy health plans) leveraging millions of members and ‘medical management’ and network contracting infrastructure, how can an army of independent and often clueless if not dis-empowered agents (patients, members sometimes at the point of service) do better?

[Editor’s note: one reason for an earlier post on the need for a ‘new IPA’ i.e., independent patient association]

This testimony was provided by Josh Libresco to the Department of Managed Care in California during their consideration of rate hikes by health plans.

Testimony1

Testimony2

 

 

 

Time for a New Manifesto?

With this history as both context and some may say ‘institutional memory’, I thought I might make sense to take heed of what’s become rather well known in the 12 step recovery community (from AA to Al-anon and many derivatives) which is to admit our ‘addiction’ to the arguably ‘easier softer path’, i.e., fee for services medicine.

Perhaps this can be a manifesto of sorts to embrace as we embark upon this journey for volume to value based healthcare?

Adapted from the 12 Steps of Alcoholics Anonymous

1. We admitted we were powerless over our addiction to fee-for-services medicine – that our healthcare delivery and financing model had become unmanageable.

2. We came to believe that power greater than ‘do more to earn more’ incentives (global capitation) could restore us to sanity and move the needle on the triple aim.

3. Recognizing the finite nature of our healthcare resources we made a decision to dedicate our will and our professional lives to the pursuit of the triple aim and its associated sustainable healthcare economy.

4. We made a searching and fearless moral inventory of our contributions to a seemingly ‘resistance is futile’ healthcare borg.

5. We admitted in our silo-ed huddles and to one another the aggregate nature of our [well intended, though] collective wrongs.

6. We were entirely ready to have a calling to the ‘greater good’ that transforms a profit maximization – at any expense- operating culture.

7. We humbly asked our ‘higher power’ for faith in a value based healthcare economy and for the support to let go of the fee for services addiction.

8. We made a list of all patients, payers, or employers we had harmed, and became willing to make amends to them all.

9. We made direct amends to such stakeholders wherever possible, except when to do so would injure them, others or our ability to facilitate the journey from volume to value.

10. We continued to take personal inventory and when we felt the temptation to default to legacy inertia – promptly admitted it.

11. We sought through mindfulness, meditation and collaboration to improve our vision and practice of value based healthcare, sharing openly for the knowledge, capacity and willingness to deliver on this historically elusive goal.

12. Having had a professional – if not spiritual – awakening as the result of these steps, we tried to carry this message to one another and practice these principles in all our affairs.

 

Accountable Care, ACO, Affordable Care Act

Is Evolent Health the ‘New, New’ Healtheon?

By Gregg A. Masters, MPH

There are parallels worth considering!Evolent Health S1 Filing

But first for those who’s event horizons’ don’t reach back to the Healtheon era (mid to late 1990’s) a little history may help with the construction of this narrative. Perhaps the dots are optimally connected by the talented and best selling author Michael Lewis in his book ‘The New, New Thing‘ (a reader’s digest version of Jim Clark’s impact is here) wherein Lewis profiles Silicon Valley Healtheonculture and the ‘pre-mature’ rise of an ambitious company who intended to ‘fix healthcare’ via technology – Healtheon (the vestiges of which exist today as WebMD and Emdeon). And for those of you history buffs, who want a deeper dive into the story, see ‘What The Heck Is Healtheon?

Dots Connected?

EvolentHealthBoth Evolent Health and Healtheon are (or were) ‘transformation plays’ with an ‘on the come‘ revenue upside tied to the expected (almost inevitable) market restructuring from fee-for-services medicine to an expanding book of ‘alternative payment arrangements’, i.e., capitated or fixed price healthcare (‘generation 1.0’ of bundled payment via case rates, DRGs, global or service tiered per diems, etc., as the concept of ‘valued based’ care had yet to penetrate popular healthcare lexicon).

In sum, the rather over-simplified claim for Healtheon’s upside to Wall Street is paraphrased as follows:

‘[Healtheon] would use the power of computing and the Internet to revolutionize the health-care industry, stripping away its inefficiencies and inequities and streamlining it for the new millennium.’

Here’s the company description lifted from Healtheon’s registration statement in 1995:

Healtheon Company description

Fast forward some 19+/- years later, according to Evolent Health’s S1 filing here’s their story:

We are a market leader and a pioneer in the new era of healthcare delivery and payment, in which leading health systems and physician organizations, which we refer to as providers, are taking on increasing clinical and financial responsibility for the populations they serve. Our purpose-built platform, powered by our technology, proprietary processes and integrated services, enables providers to migrate their economic orientation from fee-for-service, or FFS, reimbursement to payment models that reward high-quality and cost-effective care, or value-based payment models. By partnering with providers to accelerate their path to value-based care, we enable our provider partners to expand their market opportunity, diversify their revenue streams, grow market share and improve the quality of the care they provide.

We consider value-based care to be the necessary convergence of healthcare payment and delivery. We believe the pace of this convergence is accelerating, driven by price pressure in traditional FFS healthcare, a regulatory environment that is incentivizing value-based care models, a rapid expansion of retail insurance driven by the emergence of the health insurance exchanges and innovation in data and technology. We believe providers are positioned to lead this transition to value-based care because of their control over large portions of healthcare delivery costs, their primary position with consumers and their strong local brand.

Today, increasing numbers of providers are adopting value-based strategies, including contracting for capitated arrangements with existing insurance companies, governmental payers or large self-funded employers and managing their own captive health plans. Through value-based care, providers are in the early stages of transforming their role in healthcare as they attempt to defend their existing position and capture a greater portion of the more than $2 trillion in annual health insurance expenditures. While approximately 10% of healthcare payments are paid through value-based care programs today, including through models created by systems like UPMC, Kaiser Permanente and Intermountain Healthcare, it is estimated that this number will grow to over 50% by 2020. There were 120 provider-owned health plans as of 2010 and this number continues to grow. The number of ACOs constructed to manage capitated or value-based arrangements with existing insurance companies or government payers grew to 742 by the end of 2014.

We believe the transformation of the provider business model will require a set of core capabilities, including the ability to aggregate and understand disparate clinical and financial data, standardize and integrate technology into care processes, manage population health and build a financial and administrative infrastructure that capitalizes on the clinical and financial value it delivers. We provide an end-to-end, built-for-purpose, technology-enabled services platform for providers to transition their organization and business model to succeed in value-based payment models. The core elements of our platform include:

• Identifi®, our technology platform;
• an integrated technology, proprietary process and clinical services model;
• long-term, embedded and aligned partnerships with health systems;

So the mission’s of both were similar if not identical in terms of the re-structuring upside. They vision a disruptive technology play layering efficiencies into (if not picking off the low hanging fruit) of a change resistant confederation of legacy healthcare interests inclined towards internecine warfare (dis-organized medicine writ large, but primary care v. specialty care in particular and the grand canyon divide between payors and providers to get beyond the simple calculus of ‘your revenues are my expenses’).

What’s different today?

Times have indeed changed, AND the stakes have risen considerably. From a macro-economic perspective the ‘cost shifting’ shell game is officially over as today it’s about ‘total costs of care’ (the triple aim and the new focus at the level of population health) and not shifting liabilities from ‘my P&L to yours’.

Yet, the fundamental problem of a healthcare non-system incentivized by a ‘do more, earn more’ payment model continues to consume a dis-proportionate share of the national economy despite both public and private sector efforts to restrain its appetite. Yet, I see at least four underlying market considerations belying this otherwise ‘deja vu’ insight.

  1. The presumptive value prop of technology (and its enabling infrastructure) is more prevalent, powerful and affordable today than it was in the 90s.
  2. The share of GDP the healthcare spend accounts for in the 90s hovered in the 9-10% range, whereas today that share is closer to 18% where nearly 1 in 5 dollars spent in the U.S is parked inside a seemingly insatiable healthcare appetite.
  3. The healthcare reform or health system re-design imperative, once contained behind the closed doors of health systems, risk bearing physician entities, corporate board rooms of purchasers or their health plan proxies and even the halls of both State and Federal Government is now ‘out of the barn’.
  4. Anticipating the trend growth (i.e., the impending bankruptcy of the U.S Treasury) in Medicare and Medicaid spending CMS has upped the ante in the value based payment glidepath by targeting 50% of their spend to be channeled via value based payments year end 2018; see: ‘Better Care. Smarter Spending. Healthier People: Paying Providers for Value, Not Volume‘.

This change if not re-invention mandate is a national if not global conversation and quest. In other words, the healthcare spend will sink not just companies, but countries if we do not find a satisfactory path to a sustainable healthcare ecosystem.

So maybe this time things are different (those above and perhaps many others) to make this reach and business model both practical and scalable for at times ‘impatient’ investors.

So ‘Ladies and Gentlemen, start you engines’. And by all means do buckle in, this ride will no doubt be a fun one!

Accountable Care, ACO

An ACO Update via Leavitt Partners

By Gregg A. Masters, MPH

Just released is the continuing pulse of the accountable care industry (not just ACOs per se) via the consulting firm branded with the imprimatur of a former Secretary of HHS Michael Leavitt who opines from the Red State of Utah on the progress made by market driven initiatives outlined leavitt_acosin the Patient Protection and Affordable Care Act (ACA).

I will add my thoughts to the Leavitt commentary shortly, but the one slide that caught my attention y/e 2014 was the crossover by provider type from physician led to institutionally (hospital system) led ACOs.

One might say that the traditional revenue side vs. cost basis of a hospital group is now at the head of the class of ACO innovation is the wrong form of ‘disruptive leadership’.

Yet, it’s interesting to note that the American Hospital Association (AHA) is a principal partner if not co-sponsor of the report. Might this be a filtering outcome of the ‘fox guarding the hen house‘ or even the aggregate impact (conscious or otherwise) of strategy driven choices by CEOs of U.S. Health Systems?

By way of context, as a long as hospitals maintain their ‘revenue center’ primacy vs, their actual role (in the sustainable healthcare ecosystem food chain) as the true ‘cost centers’ they are – at least in legally, financially and clinically integrated delivery systems or networks (IDNs), how can ‘hospital culture’ be expected to pro-actively cannibalize a bread-and-butter fee-for-services business model in a reimbursement paradigm largely dominated by volume driven incentives even in 2015? Only a disinterested third party (aka physician led ACOs) can re-engineer the needed disruption of maldistributed, asset concentrated overpriced hospital services.

For the complete Leavitt Partners report click here.

ACOs by sponsor type Leavitt Partners

Accountable Care, ACO, Affordable Care Act

ACO Alignment Summit

by Gregg A. Masters, MPH

Day one of the ACO Alignment Summit kicked off in Alexandria, Virginia with excellent presentations from Diwen Chen, Executive Director, Payment Innovation and Accountable Care, Dignity Health, and Michael Donahue, MBA, Vice President, Network Development and ACO Activities for Eastern Maine Healthcare System (EMHS).Dignity Health

Dignity Health a hospital system founded in 1986 with 38 hospitals is the fifth (5) largest hospital provider in the nation and the largest non-profit health system in California. Dignity Health operates 32 facilities in California, with three (3) in Arizona and three (3) in Nevada. The Dignity Health system medical staff boasts 9,000 affiliated physicians, and 500,000 members via four sponsored health plans.

EMHS Eastern Main Healthcare System (EMHS) is a regional integrated delivery system serving all of central, eastern, and northern Maine. Beacon Health, LLC is the organizational model which supports EMHS’ designation as a Pioneer Accountable Care Organization.

Beacon Health, LLC is one of the remaining 19 Pioneer ACOs piloting a program designed to improve the coordination, efficiency, effectiveness, quality, and cost of healthcare.

[NOTE: For more information see: EMHS Beacon Health Pioneer Accountable Care Organization.]

ACOs are key drivers implementing the ‘triple aim’ vision of the Affordable Care Act.  At core the intention is to improve the care delivered to Medicare patients, while transforming the overall healthcare delivery system from volume to value. EMHS deploys approximately 8,000 people in this transformative commitment to accountable care.

According to CMS Beacon Health, LLC experienced the following since admission to the program:

Performance Year 1 (2012): Gross Savings  5.0%

Performance Year 1 (2012): Gross Savings $4.05 Mil

Performance Year 1 (2012): Earned Shared Savings Payments $2.03 Mil

Performance Year 2 (2013): Gross Savings 5.6%

Performance Year 2 (2013): Gross Losses  $-6.26 Mil 

Performance Year 2 (2013): Earned Shared Savings Losses3 $-2.89 Mil 

A limited recap of the day’s presentation highlights is below:

The twitter transcript is herethe updated analytics report here and dashboard here. Reach analytics for Day 1 are pasted below:

Analytics Day 1 ACO Alignment Summit