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Is Value Based Care Just Regulatory and Reimbursement Hoop Jumping?

Posted on September 17, 2018 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In theory, we all love the move to value based care. Why aren’t we paying healthcare providers to improve care. It just makes sense. In fact, the fee for service model in many ways feels so unnatural. While the theoretical value based care sounds good, getting there is much easier said than done. Translating the simple idea of value based care into regulations and reimbursement is a really hard thing to do.

I’ve often asked the question, “Is value based care just a regulation and reimbursement hoop jumping activity?” Does he who can jump through the hoops the best win? Or is it really the person who improves the care the most win?

I found two Twitter threads discussing ACOs that may shed some insight into not only ACOs, but the shift to value based reimbursement. Plus, I think it might help to answer the question above.

The first ACO thread is in response to an NGACO report from CMS that was shared by David Muhlestein.

In response to David’s tweet, Adam Solomon offered his perspectives in this tweet storm:

Sorry to chime in late. Our NGACO experience was very interesting. Our benchmark was based on our historical utilization for a similarly attributed population. They then added a very low trend factor to come up with a final target.

In the end, our PBPM cost was actually lower than the benchmark, but we still owed over $5 million to CMS. What happened?

Because the baseline year risk was calculated in the 2014 model and year 1 was the 2016 model, they couldn’t directly compare the acuity of the two populations. Therefore, the utilized a ratio comparing our trend to that of others. Our RAF score didn’t jump as much as theirs.

So our RAF “decreased” suggesting our active population was healthier than our baseline. That accounted for over $2.5 million dollars of “loss.”

The other hit was the way they calculated stop loss. Sure, there was an elective level of aggregate stop loss, but they also assigned a PBPM cost for individual stop loss based on expectations for number of patients with claims over the 90th percentile.

Because California has historically high costs, they estimated that we would have an abnormally high number of patients that exceeded that threshold. That was something like a $20 PBPM hit or another $3.5 million of artificial cost to us.

In the end, although we saved CMS money, we still needed to pay them for our “loss.”

Separate from that, the NORC Report noted above uses a different methodology to estimate savings. Instead of using ourselves as a baseline, they used a regional reference population.

The saddest part for us was that our utilization was always at the top end with little room for improvement. As an example, here’s admits/k for year 2 NGACOs. We’re dark blue.

In a separate tweet storm, Farzad Mostashari, Former National Coordinator at ONC and now Founder of Aledade offered this look at the ACO results:

1/ 2017 #MSSP #ACO Results!
ACOs have scaled rapidly across the country!

In aggregate, the 472 ACOs were accountable for nearly 9 million Medicare beneficiaries and $95 Billion- that’s a quarter of all fee for service, and almost half of the entire Medicare Advantage market.

2/ If you add up all the actual costs versus benchmarks, these 472 ACOs were collectively $1.1B under their benchmarks (more on whether that’s the right counterfactual later).

Medicare shared $780 million in payments with the ACOs, netting the taxpayer $313M

But wait!

There’s lots of evidence that the benchmark under-estimates the savings produced. @JMichaelMcW et al have shown convincingly that a true “difference in difference” approach would show substantially higher net impact.

The green eyeshades folks at CMS OACT said add 60%

3/ So that means that the best guess for MSSP savings is actually $1.75B in 2017, with Medicare paying out $780M (45%)- not a bad deal for the taxpayer!!!

That does NOT count savings that come from lower costs to the taxpayer from Medicare Advantage rates that are keyed off FFS

4/ Here’s how the CMS actuaries put it:

And on quality- the average ACO earned 92% on their quality scores- and the scores improve the longer you are in the program according to the ACO Rule’s Regulatory Impact Assesment.

(The Aledade average quality score applied was over 95%, and as high as 99.8% #GoKANSAS)

6/ Lemme say that again….

ACOs saved Medicare over a Billion dollars in 2017.

Cheaper than FFS, cheaper than MA.

And they did it without cutting payments to doctors or narrow networks

And they did it with higher patient quality.

That’s called delivering what was promised

7/ the Track 1 ACOs more than held their own here

Best guess is that Track 2/3 generated 190M in savings (w 60% spillover) and received $95M (50%)

Track 1: $1.5B in savings, $685M in payments (44%)

(I’m still a believer in moving to 2-sided risk to help weed out ACO squatting)

8/ You know what was a great investment? Giving small and rural physician-led ACOs an advance payment to help them invest in infrastructure and setup costs.

It was critical to the success of several of our @AledadeACO

More commercial payors should do this!

9/ But what this initial release does not help us do is see which type of ACOs are creating the most value.

My guess is that it’s not much different from what the CMS actuaries found for PY 2016- ACOs that include hospitals and directly control more of the cost of care do worse

10/ The “low revenue” ACOs (in the OACT analysis – less than 10% of total cost of care came to them) were only a third of the lives in the program, but generated roughly 98% of the savings.

THAT is why in the ACO Rule CMS proposed letting them stay in low risk models longer

11/ That was the entire thesis behind “the paradox of primary care leadership” that informed the founding of @AledadeACO

That is also why @AledadeACO partners with independent physician practices, not hospitals like others do.

Health Reform and Physician-Led Accountable Care
Even though most adult primary care physicians may not realize it, they each can be seen as a chief executive officer (CEO) in charge of approximately $10 million of annual revenue. Consider that a t…
https://jamanetwork.com/journals/jama/fullarticle/1861359

12/ A quick analysis by the amazing @Travis_Broome divides these 2017 results by whether the ACOs included a “facility/CCN” (CAH, RHC, FQHC don’t count for this purpose) –

Same pattern- 95% of the savings are coming from the ACOs that don’t include hospitals.

13/ Only 3.5M of the 9M ACO-attributed benes were cared for by the smaller ACOs that didn’t include a hospital facility- and they generated 95% of the savings.

If you’re an independent practice seeing these results and the policy direction, why would you join a hospital ACO?
So how did @AledadeACO do?

We are always very transparent with our results- even when things didn’t go our way- to look for ways to be better, and to make policies better that are holding back broader success.

This article 2 years ago was full of pain.
The Opportunities and Challenges of the MSSP ACO Program: A Report From the Field
This article provides a detailed description of a Medicare Shared Savings Program accountable care organization (ACO)’s actions and results, to increase understanding of the challenges and opportunit…
https://www.ajmc.com/journals/issue/2016/2016-vol22-n9/the-opportunities-and-challenges-of-the-mssp-aco-program-a-report-from-the-field

15/ This was a good year for @AledadeACO

Only 1/7 freshmen ACOs made savings- but we have learned to set expectations- it’s a long game.

But 5/8 ACOs that were sophomores or older will get checks.

And 2/3 that didn’t get MSSP crushed it in commercial contracts.

16/ But I’m more proud that EVERY ONE of our @AledadeACO have measurably improved health for the patients we are accountable for.

We have increased wellness visits, transitional care, and chronic care management- and that’s translated into lower ED visits and readmissions

17/ So where do we go from here?

The #MSSP #ACO program has been a hugely successful motivator of nationwide transformation, but it can be reformed, and I believe @SeemaCMS is on the right track.

Here’s what I would expect might change between the NPRM and the final ACO rule:

18/ The GlidePath to risk reduces ACO squatting, and brings revenue-based downside risk to MSSP, but the lowered gainshare in 1st 2 years (25%) is not enough to get new entrants and ACO investments.

(as suggested) “low revenue” ACOs should get higher gain-share and lower MSR

19/ The refined benchmarking method gives greater predictability by allowing risk adjustment and regional trending-which is great!
But the cap on risk adj (3% over 5 years?!) don’t control for rising risk and introduces gaming on falling risk

Instead of a cap, do renormalization

20/ Concern about “windfall profits” led to an ill-advised proposal to cap regional efficiency at 5% – In Medicare Advantage if you are efficient, you get to keep the difference, which has spurred huge innovation in the space. why blunt improvement? 100% tax brackets are not good

21/ Credit to CMS for trying to fix the unintended “regional comparator” problem- where rural ACO savings are reduced in direct proportion to market share. But the “national trend blend” proposal makes NO SENSE.

Let’s just take ACO benes out of the regional comparison please!

22/ But the biggest impact of these results on the proposed rule should be on the idea that the way to benefit the Trust Fund is to protect it from ACO earnings.

These caps, etc reduce ACO earnings- and ACO motivation/participation- and therefore reduced benefit to Medicare

23/ The NPRM RIA estimates through 2024 these caps push $390M in lower ACO earnings, but lower ACO participation under these policies will INCREASE claims costs by $60M- and would prevent beneficiaries from receiving the benefits of the program. That’s not the right balance

24/ The magic of accountable care is when physicians & Medicare partner together to sustainably align financial incentives, help beneficiaries and the Trust Fund.

Medicare hasn’t behaved like some commercial payers who are still seeing zero sum. Let’s hold onto that partnership

I’ll let you be the judge after reading through these threads. Are ACOs going to really improve healthcare and lower costs? Will the best healthcare win? Or will the people who understand the government rule making process and healthcare accounting be the big winners?

As I read through these, it seems like you better get your accountants and healthcare policy experts ready. That brings joy to every doctor’s ears…I’m sure!

A Small Practice View of Healthcare IT Coming Out of #HIMSS16

Posted on March 8, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This week as I slowly recover from the #HIMSSHaze that sets in after spending a week with 41,000 of your closest friends and 1300+ vendors, I’m taking a second to think about how the small physician practice fits into the future of healthcare IT that was presented at HIMSS 2016.

As the graphic at the bottom of this post shows, just over 40% of attendees at HIMSS are providers. Of course, provider is a pretty broad term and that has to also be paired with the other number on that chart that 30.5% of attendees are part of the C-Suite. Even scarier is that only 2.2% of HIMSS registrations identified themselves as clinicians.

Those who read this blog regularly likely remember that I already wrote about physicians and patients missing at HIMSS. These numbers seem to prove this out. It’s unfortunate, because that means that the physician voice is largely going to be missing in many of the conversations that happen at a show like HIMSS.

With this in mind, it’s not surprising that I think the future for the small practice is on shaky ground. Many of the solutions presented at HIMSS are going to be hard for a small practice to afford. At some point these health IT solutions will be so good that they’ll become the standard of care. Once that happens, where does that leave the small practice provider who can’t afford these high tech solutions?

Considering many small practices aren’t joining in these conversations, I think it’s going to leave many small practices up a creek without a paddle. No doubt there’s a large portion of the physician population that are betting that retirement will come before this becomes a reality. Others probably think that the worst that could happen is that they’ll have to work for a large organization.

Despite this rather negative outlook on the future of small practices, there is some hope. When you look at the work that Farzad Mostashari is doing at Aledade to make accountable care and valuable based reimbursement available to the small practices you can see a future where small practices can survive even in this changing reimbursement landscape.

I think there are two models that I see emerging to allow small practices to keep some autonomy and survive in this changing healthcare world. First, small practices have to join together with other small practices to be able to create a large enough entity to be able to share in the costs associated with this future technology and to be able to compete with much larger hospital systems. Second, we need organizations like Aledade that help small practices survive by spreading their resources across a diverse group of small practices.

There is strength in numbers. So, whether the small practices form together themselves or whether health IT vendors essentially create a network of small practices, either option requires small practices to combine their efforts in order to survive. It reminds me of this clip from the film Finding Nemo. Small practices need to start “Swimming Together!”

Here’s a look at the registration numbers for HIMSS 2016:
HIMSS 2016 Registrations by Title and Worksite

A 6 Step Guide to Succeeding as an ACO

Posted on June 18, 2015 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Farzad Mostashari’s company, Aledade, raising $30 million is a good sign that healthcare organizations are going to be spending a lot of time and money figuring out these new ACO and value based reimbursement models. If you’re a healthcare organization that hasn’t started learning about ACOs, here’s a good whitepaper to start.

The whitepaper is titled “Succeeding as an ACO: A 6-Step Guide for Health Care Organizations” and does a lot more than just talk about the 6 steps to building an ACO. It covers ACO in a pretty thorough way. However, the 6 steps are pretty valuable as well:

1. Understand Your Costs
2. Reduce Out-Migration from Your Network
3. Maximize Pay-for-Performance Reimbursement
4. Identify Early Opportunities for Utilization Reductions
5. Support Chronic Care and Disease Management
6. Predict Who Will Develop Issues

Is your healthcare organization ready for the changing reimbursement model and ACOs? If you’re not sure, read through this FREE whitepaper and you’ll have a better idea of what’s happening and how you want to position yourself and your organization in this changing reimbursement environment.

Farzad Mostashari Launches New Startup Company Aledade – A Physician-Led ACO in a Box

Posted on June 18, 2014 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I know when I first heard that Farzad Mostashari landed at the Brookings Institution after leaving his position as National Coordinator, I couldn’t imagine it being Farzad’s long time home. However, it was a really smart short term landing spot that would give him the opportunity to prepare for his next adventure.

We just learned that Farzad is now entering the startup world with the launch of a new company called Aledade which partners with primary care doctors to form ACOs. In a blog post introducing the startup, Farzad said “The world of start-ups may not be the usual path for those leaving a senior federal post, but it’s the right decision.” I’m not sure the career path of former senior federal employees, but I think the startup world is going to fit Farzad really well. Plus, who would you rather have leading your ACO efforts than Farzad?

Maybe we should have been able to predict this move if we’d listened closely to Neil Versel’s interview with Farzad Mostashari at HIMSS. As Neil comments, “Always the champion of the little guy in healthcare, Mostashari also brought up the notion of physician-led ACOs, or, as he called it, the “Davids going up against the Goliaths.””

Aledade has received $4.5 million in investment from Venrock and the company is targeting four areas of the country: Delaware, Arkansas, Maryland and the metro New York area (not surprising considering Farzad’s past connection to NYC).

What’s also interesting is that Aledade is building their financial model on a performance model. They aren’t requiring any up-front cost to physicians and instead are opting to make money when the physicians realize savings. I’ll be really interested to see how this works out in practice. Many of the savings that ACOs have realized could be considered fuzzy math. Although, maybe Aledade will just take a percentage of the additional ACO payments the physician ACO receives.

I’ll be interested to see what technologies come out of Aledade. I can’t imagine them launching a full EHR and so they’ll have to integrate whatever they do with dozens of EHR companies. This will be a tremendous challenge. Will they build the technology in house or just partner with an outside vendor?

I’ve heard Farzad say that the move towards value based reimbursement was happening quicker than most of us realize and that the fee for service and value based reimbursement models can’t happen at the same time. The launch of Aledade is a great example that he’s not just paying lip service, but he’s fully committed to this change.